The People’s Picture Company Inc. and its affiliates (collectively, “The PPC” or “we”) takes steps intended to meet privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation. The purpose of this statement is to inform our customers and other individuals we deal with (“you” or “your”) how we collect, use, disclose and protect your personal information both on and off-line. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This statement applies to our collection, use and disclosure of personal information in Canada. This statement does not apply to information about our employees or to information that is not personal information.
Personal Information We Collect
The PPC and its agents and representatives collect personal information in a number of circumstances in the course of its business. Since the information you submit to us online may not be encrypted, we cannot guarantee the absolute privacy of that information. Personal information we collect includes:
- contact information such as name, address, email address and telephone number;
- information provided when you register or otherwise provide information on our website;
- information provided when you purchase our product(s) (credit card information is not collected—it is kept private by PayPal);
- information provided when you complete questionnaires or surveys;
- information provided when you participate in a promotion or contest;
- information provided otherwise such as by telephone, by mail or through our website;
- records of customer calls or product-related comments or inquiries;
- such other information we may collect with your consent or as permitted or required by law.
Use of Personal Information
The PPC generally uses personal information for the following purposes:
- receiving and replying to your requests, inquiries and comments;
- with your consent, sending you information about products and promotions offered by The PPC;
- with your consent, sending coupons from time to time;
- providing customer service;
- administering promotions and contests;
- creating a database of individuals who have registered to receive information from us;
- improving our products;
- managing our business, including customer relations;
- ensuring the security of our business operations including our website;
- managing, administering, collecting or otherwise enforcing accounts;
- maintaining business records for reasonable periods and as required by law, and generally managing and administering our business, including defending and prosecuting legal claims;
- meeting legal, regulatory, insurance, security, accounting and processing requirements;
- purposes disclosed at the time of collection of personal information; and
- otherwise with consent or as permitted or required by law.
Collection of Your Personal Information
The PPC collects personal information for the following commercial purposes:
- to establish and maintain responsible commercial relations and to provide ongoing service, and communication;
- to understand customer needs, trends and preferences;
- to evaluate, develop, enhance, market or provide The PPC’s products and services;
- to manage and develop The PPC’s business and operations;
- to meet legal and regulatory requirements;
- to protect The PPC’s against error and fraud; and
- for any other purpose to which an individual consents.
Disclosure of Your Personal Information
The PPC may disclose personal information, including in the following circumstances to:
- a person who in the reasonable judgement of The PPC is seeking the information as an agent;
- a company or individual retained by The PPC to perform functions on its behalf, such as research or data processing;
- a company or individual retained by an individual, who represents that it expressly is entitled to receive such individual’s personal information, or in the reasonable opinion of The PPC implicitly is entitled to receive such individual’s personal information;
- a company or individual retained by The PPC for the evaluation, development, enhancement, marketing or provision of any of The PPCs’ products or services;
- a public authority or agent of a public authority, if in the reasonable judgement of The PPC, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information;
- a third party or parties, where the customer consents to such disclosure or disclosure is required by law;
- professional advisors, consultants, investigators and adjudicators in defending and prosecuting legal claims.
In addition to the above, personal information may be disclosed to our affiliates (including outside of Canada) for internal audit, management, billing, administrative and other general business purposes.
Service Providers.The PPC may transfer personal information to outside agents or service providers (including affiliates of The PPC acting in this capacity) that perform services on our behalf, for example data processing services such as mailing, call centre, billing, marketing, information technology or data hosting or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. Some of these service providers or affiliates may be located outside of Canada, including in the United States, and your personal information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for the purposes described in this Privacy Statement. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to legal requirements in Canada, the United States and other foreign countries applicable to our affiliates, agents and service providers. For example we may be required to disclose personal information due to lawful requirements to disclose personal information to government authorities in those countries.
Business Transactions.Personal information may be used by The PPC and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of The PPC or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples:
- permitting those parties to determine whether to proceed or continue with the transaction
- fulfilling reporting, inspection or audit requirements or obligations to those parties. Assignees or successors of The PPC or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Statement.
Legal, Regulatory, etc.The PPC may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to The PPC or our agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).
Our Website/The Internet
Active Information Collection: The PPC’s website actively collects information from its visitors both by asking you specific questions and by permitting you to communicate directly with us and other users via e-mail and/or feedback forms. Some of the information that you submit on the website may be personal information. Collection, use and disclosure of information actively collected from you have been described.
The PPC website may use and combine such passively collected anonymous information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the site for your use. Such passively collected anonymous information is not combined with personal information collected elsewhere on the website, unless you have consented to have your personal information collected in conjunction with this passive information.
Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide personal information necessary for a service you have requested or the purpose is obvious). You may be asked to provide your specific consent in some special and specific circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, you are deemed to consent to our collection, use and disclosure of such personal information for the purposes identified or described in this privacy statement, if applicable, or otherwise at the time of collection.
You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Note also that where we have provided or are providing products or services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to Canadian and foreign government entities as required to comply with laws, and reporting on credit information after credit has been granted, if applicable).
The PPC collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
About Teenagers and Children
Children under the age of 13: Generally, we do not intend to collect personal information from individuals under the age of 13 without parental consent. We may, from time to time, offer a contest where the child under the age of 13 can enter in which case the personal information is used for purposes of administering the contest and determine a winner. If a child under 13 has provided us with personal information, without parental consent we ask that a parent or guardian of the child contact us to request that this personal information be deleted from our records. We will use reasonable efforts to delete the child’s personal information from our existing files. We encourage parents to talk to their children about their use of the Internet and the personal information they disclose to Websites or otherwise.
We will use reasonable efforts to delete all contact and other personal information obtained from a teenager if a parent or guardian notifies us that they wish to withdraw consent for the collection of a teenager’s personal information.
We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the personal information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and mandataries of The PPC who require access to your personal information in order to fulfil their job requirements will have access to your personal information.
Links to Other Websites
This website may contain links or references to websites to which this Privacy Statement does not apply. The PPC is not responsible for the data collection and use practices of companies or organizations to which this website may provide links.
Privacy Statement Changes
This Privacy Statement may be revised from time to time. If we intend to use or disclose Personal Information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us or check our website periodically at www.livingdownstream.com to obtain a current copy of this statement. We urge you to request and review this Privacy Statement frequently to obtain the current version. Your continued provision of Personal Information or use of our services following any changes to this Privacy Statement constitutes your acceptance of any such changes. This privacy statement is effective as of December 1, 2010.