Scope of this Policy
What is Personal Information?
What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of individuals with whom we interact. This includes:
- contact and identification information, such as name, address, telephone number and e-mail address;
- product and service related information concerning the products and services we provide to, or receive from, you, including with respect to the service, maintenance and repair of such products;
- credit and financial information such as payment methods and preferences, and billing and credit history;
- business relationship information, including information related to your agreements, preferences, advisors and decision-makers; and
- customer relationship information such as customer service requests and feed-back and information requested or provided by or from you.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.
As a general rule, IncrediGrow collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). The third parties that we may collect information from include credit reporting agencies (for the purpose of conducting a credit check where you wish to obtain credit from us).
From time to time, we may utilize the services of third parties (including other members of the IncrediCorp Group) in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
Why Do We Collect Personal Information?
IncrediGrow collects personal information to enable us to manage and develop our business and operations, including:
- the verify identity (for example, name, address, telephone number and birth date, if applicable);
- to verify creditworthiness;
- to establish, maintain and manage relations with you so that we may provide you with, or receive from you, the products and services that have been requested (for example, we will use your personal information to establish your identity and location so that we may accurately deliver and bill for the products and services that you request);
- to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
- to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services and work to improve the products and services that you provide to us;
- to be able to inform you of products and services that other members of the IncrediCorp Group or third parties that we have carefully selected as partners may wish to offer you, including sending you information promoting the products and services of those members or partners;
- to be able to comply with your requests;
- to protect us against error, fraud, theft and damage to our goods and property;
- to enable us to undertake our environmental, health and safety activities, including incident planning, response and investigation;
- to enable us to comply with applicable law or regulatory requirements (for example, we may collect personal information to satisfy the obligations imposed on us by various regulatory boards or agencies to follow procedures mandated by such boards or agencies in respect of the provision of our products and services); and
- any other reasonable purpose to which you consent.
How do we Use Your Personal Information?
We use your personal information:
- for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information, which consent may be express, deemed or implied, as explained below.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When Do We Disclose Your Personal Information?
Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of IncrediGrow’s regular reporting activities to other members of the IncrediCorp Group and to other IncrediGrow affiliates outside Canada;
- to protect the rights and property of IncrediGrow (for example, to collect a debt or to protect ourselves from fraud);
- when we require legal advice from a lawyer;
- in an emergency that threatens an individuals life, health, or personal security;
- when the personal information is available from a public source (for example, the telephone book) or
- with your consent, where such consent is required by law.
Your Consent is Important to Us
It is important to us that where we collect, use or disclose your personal information we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you accept our products or services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time.
As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to, or acquire products or services from, you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Human Resources Manager.
How Long Do We Retain Your Personal Information?
If we use your personal information to make a decision that directly affects you, we will retain that personal information for at least one year so that you have a reasonable opportunity to request access to it.
Except as stated above, as otherwise permitted, or required by applicable law or regulatory requirements, Incredigrow endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).
Accuracy of Your Personal Information
Since we use your personal information to provide products and services to you, or to obtain products and services from you, it is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please let us know. In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
How is Your Personal Information Protected?
Incredigrow endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. Incredigrow will also use appropriate security measures when destroying personal information, and instead of destroying or erasing your personal information, may make it anonymous such that it cannot be associated with or tracked back to you.
Access to Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Human Resources Manager using the contact information set out below. Any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. We may charge you a minimal fee to access your personal information, however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Human Resources Manager.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
Questions or Complaints?
We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner applicable for your jurisdiction.