Privacy Policy

LEVY’S LEATHERS LIMITED AND CLARKE’S QUALITY CASES LTD.

Personal Information and Privacy Policy

Privacy Policy update for www.levysleathers.com effective January 18th, 2016

This Application collects some Personal Data from its Users.

Data Controller and Owner

Levy’s Leathers
levys@levysleathers.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: First Name, Last Name, Phone number, Email address, Cookie and Usage data.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.
The Personal Data may be freely provided by the User, or collected automatically when using this Application.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.
Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Contacting the User, Remarketing and Behavioral Targeting and Managing contacts and sending messages.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contacting the User

Contact form (This Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: Email address, First Name, Last Name and Phone number.

Managing contacts and sending messages

These services make it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Remarketing and Behavioral Targeting

These services allow this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.

This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

AdRoll (Semantic Sugar, Inc.)

AdRoll is an advertising service provided by Semantic Sugar, Inc.

Personal Data collected: Cookie and Usage data.

Place of processing : USA – Privacy Policy – Opt Out

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

Personal Data collected: Cookie and Usage data.

Place of processing : USA – Privacy Policy – Opt Out

Twitter Remarketing (Twitter)

Twitter Remarketing is a Remarketing and Behavioral Targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.

Personal Data collected: Cookie and Usage data.

Place of processing : USA – Privacy Policy – Opt Out

Remarketing through Google Analytics for Display Advertising (Google)

Google Analytics for Display Advertising is a Remarketing and Behavioral Targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookie and Usage data.

Place of processing : USA – Privacy Policy – Opt Out

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System Logs and Maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.

To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda’s servers.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookie

Small piece of data stored in the User’s device.

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The following is an outline of the Levy’s Leathers Limited/Clarke’s Quality Cases Ltd. Personal Information and Privacy Policy. This policy came into effective January 1, 2004. Any questions, comments or issues pertaining to this policy should be forwarded to our Privacy Officer, Russell W. Cassidy, located at 190 Disraeli Freeway, Winnipeg, Manitoba, R3B 2Z4.

Private sector organizations must follow a code for the protection of personal information. The code was developed by business, consumers, academics and government under the auspices of the Canadian Standards Association. It lists ten (10) principles of fair information practices which form the ground rules for the collection, use, retention, disclosure and security of personal information. These principles give individuals control over how their personal information is handled in the private sector. The ten (10) principals that business must follow are:

  1. Accountability
  2. Identifying purposes
  3. Consent
  4. Limiting collection
  5. Limiting use, disclosures and retention
  6. Accuracy
  7. Safeguards
  8. Openness
  9. Individual Access
  10. Provide Recourse

Levy’s Leathers Limited and Clarke’s Quality Cases Ltd. (collectively referred to as the company) is committed to protecting your privacy and ensuring personal information confidentiality. We ensure compliance by our staff with strict standards of security and confidentiality.

The purpose of our Privacy Code is to inform you about our privacy protection practices and our reasons for collecting information. Our Privacy Code applies to all aspects of our Business including our employees, customers, suppliers and business partners.

What is personal information?

For the purposes of this policy, Personal Information is defined as information about an identifiable individual such as name, address, age, identification numbers, income, opinions, evaluations, comments, disciplinary actions, employee files, credit reports, existence of a dispute between a consumer and a merchant, intentions (for example, acquire goods or services), purchase and order history and other information specifically related to an individual and/or their family.

Personal Information does not include information that does not identify specific individuals. The Privacy Policy does not apply to publicly available information such as contact information that would appear on a business card including name, title, telephone number, fax number, email address, company name and credentials or other similar information.

Accountability

Our company is responsible for all personal information under its control, including personnel information, customer information, and supplier information. We have designated an individual who is accountable for our Company’s compliance with the Privacy Legislation. Our Privacy Officer is designated on page no. 1 of this guideline.

Identifying Purposes

Our company collects, uses, obtains and discloses information about our employees, customers, suppliers and business partners for the following purposes:

Employees

  • To fulfill our agreements/commitments with our employees;
  • To enable us to communicate on a regular basis with our employees;
  • For internal purposes such as payroll matters;
  • To operate/manage and organize our business, including maintaining accounting and tax records;
  • For any other purpose for which we have been expressly or implicitly authorized;

Customers

  • To establish and verify identity;
  • To obtain credit reports;
  • To offer products and services/forwarding information about products and services by means of direct marketing either through the mail or by way of email;
  • To protect from error and fraud;
  • To investigate specific transactions or patterns of transactions in response to customer enquiries or requests;

Suppliers

  • To establish and verify identity;
  • To obtain credit reports;
  • To enable us to communicate on a regular basis;
  • To allow us to operate or manage our business by placing orders or requests for supplies and/or raw materials as required;

Personal information is collected by us primarily as the result of being engaged in a commercial enterprise. The information we require to carry on our business is collected at the time a new employee is hired into our company, or a new customer or supplier enters into business with our company.

We do not sell, rent or authorize access to any personal information, collected about or from our employees, customers or suppliers, to third parties.

Information collected in the context of our employer/employee, customer/supplier and supplier/customer relationship is ordinarily available to our company when reasonably required for any and all of the purposes listed above.

Consent

Our company will collect, use, retain and disclose information about our employees, customers and suppliers only with their knowledge and consent. The type of knowledge and consent required will vary according to the sensitivity of the information. Subsequent use of personal information will require further knowledge and consent of the employee, customer or supplier.

At all times, our company will take reasonable steps to ensure that an employee, customer or supplier, from whom information is being collected, understands the intended use of the information.

Limiting Collection

Collection of personal information is limited to information that is required to fulfill the purposes outlined in the Identifying Purposes section above. Any use of personal information, by our company, for any purpose other that the one identified at the time of collection requires the consent of the employee, customer of supplier, unless it is required by law.

Limiting Use, Disclosure and Retention

Our company will only retain personal information for as long as is reasonably necessary. Personal information shall not be disclosed for purposes other than those for which it was collected, except with the consent of the individual, customer or supplier, or when it is reasonably necessary for us to have personal information to respond to any issues arising out of our relationship that may need to be addressed at a later date. Personal information shall be retained only as is necessary for the fulfillment of those purposes.

We may provide personal information to other persons only:

  • when we have an individual’s consent whether express or implied;
  • to our suppliers or agents who assist us, and whom we can reasonably trust to respect privacy; or
  • when we are required or permitted by law to do so, or when we need to disclose the information to protect the interests of our company in the context of a legal or administrative proceeding;
  • when the life, health and security of the individual is threatened;

Accuracy

The company will make reasonable efforts to keep personal information accurate, complete and up to date as is necessary for the purposes for which it was collected. If an employee, customer or supplier finds any errors in the personal information which we have on file they must let us know and we will make the appropriate corrections. If incorrect personal information has been conveyed to any party we will undertake to make the appropriate corrections and ensure the corrected information is conveyed to the appropriate parties. Should any personal information remain in dispute, we will make a note of opinion in our records.

Safeguards

Personal information is protected by security safeguards appropriate to the sensitivity of the information. Our company ensures that all personal documents and related information are stored in a safe and secure manner. Stored electronic information can only be accessed by authorized employees of the company.

Our suppliers and agents, as part of their contract with our company, are bound to maintain confidentially and not use personal information for any unauthorized purpose. Also, when we provide personal information in response to a legal enquiry we disclose on the information that is legally required.

Computer servers that store personal information are kept in a secure environment.

When personal information is no longer reasonably necessary, it will be destroyed, erased or made anonymous, in an appropriate manner.

Openness

Our company’s Personal Information Protection Policy is available to any employee, customer or supplier requesting it (questions to be directed to our Privacy Officer).

Individual Access and Recourse

Upon request, an employee, customer or supplier shall be informed of the existence, use or disclosure of their information and shall be given access to that information. An employee, customer or supplier shall be able to challenge the accuracy and completeness of the information and have it amended as may be appropriate.

The company or companies will respond to an employee’s, customer’s or supplier’s request within thirty (30) days.

Please note we may not be able to provide personal information from our records if it contains reference to other parties, is subject to legal privilege, contains information proprietary to our company or cannot be disclosed for other legal reasons.

In the case of disagreement relating to a request for correction of information, our company, retains the right not to make any form of change or correction if we can prove that the file does not need to be changed or corrected. Our company is not required to make any change or correction if the information was communicated to our company by the employee, customer or supplier or was collected with consent.

Updating the Privacy Policy

The company reserves the right to make reasonable changes to our Privacy Policy from time to time.

Exceptions to the Consent and Access Principles

There are a number of exceptions to the requirements to obtain consent and provide access. The company may collect personal information without the individual’s knowledge or consent only:

  • if it is clearly in the individuals interests and consent is not available in a timely way
  • if knowledge and consent would compromise the availability or accuracy of the information and collection is required to investigate a breach of an agreement or contravention of a federal or provincial law
  • for journalistic, artistic or literary purposes
  • if it is publicly available as specified in the regulations

The company may use personal information without the individual’s knowledge or consent only:

  • if the company has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation
  • for an emergency that threatens an individual’s life, health or security
  • for statistical or scholarly study or research (the company must notify the Privacy Commissioner of Canada before using this information)
  • if it is publicly available as specified in regulations
  • if the use is clearly in the individual’s interest and consent is not available in a timely way
  • if knowledge and consent would compromise the availability or accuracy of the information and collection was required to investigate a breach of agreement or contravention of a federal or provincial law.

The company may disclose person information without the individual’s knowledge or consent only:

  • to a lawyer representing the company
  • to collect a debt the individual owes to the company
  • to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction
  • to a government institution that has requested the information, identified its lawful authority, and indicates that disclosure if for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law
  • to an investigative body named in the Regulations of the Act or government institution on the company’s initiative when the company believes the information concerns a breach of a federal, provincial or foreign law, or suspects the information relates to national security or the conduct of international affairs
  • if made by an investigative body for the purposes related to the investigation of a breach of an agreement or contravention of a federal or provincial law.
  • in an emergency threatening an individual’s life, health , or security (the company must inform the individual of the disclosure)
  • for statistical, scholarly study or research (the company must notify the Privacy Commissioner before disclosing the information)
  • to an archival institution
  • 20 years after the individual’s death or 100 years after the record was created
  • if it is publicly available as specified in the regulations
  • if required by law

Organizations must refuse an individual access to personal information:

  • if it would reveal personal information about another individual, unless there is consent or a life-threatening situation
  • if the company has disclosed information to a government institution for law enforcement or national security reasons. Upon request, the government institution may instruct the company to refuse access or not to reveal that the information has been released. The company must refuse the request and notify the Privacy Commissioner of Canada. The company cannot inform the individual of the disclosure to the government institution, or that the institution was notified of the request, or that the Commissioner was notified of the refusal.

The company may refuse access to personal information if the information falls under one of the following:

  • solicitor-client privilege
  • confidential commercial information
  • disclosure could harm an individual’s life or security
  • it was collected without the individual’s knowledge or consent to ensure its availability and accuracy, and the collection was required to investigate a breach of an agreement or contravention of a federal or provincial law (the Privacy Commissioner of Canada must be notified)
  • it was generated in the course of a formal dispute resolution process

For More Information or Challenging Compliance

If you have any concerns or questions about privacy and confidentiality, or any concerns about the way a request for personal information was handled, please direct your complaints or inquiries to our Privacy Officer. Our Privacy Officer has the decision making authority to resolve most privacy related concerns. However, if you are not satisfied with the way in which a complaint or inquiry was resolved, or if you have further questions about the protection of personal information in Canada, we recommend that you contact the Federal Privacy Commissioner:

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