Issue Date: March 21, 2018
This Privacy Policy describes the personal information that Arrow Group of Companies (Co) (“Arrow”, “us”, “we”, or “our”) collects about you, and how we use and share that information. Arrow is committed to protecting your personal information. This Privacy Policy applies to information we collect through our Website, mobile applications, other online products and services and various off-line sales and marketing events we conduct and/or sponsor (collectively, the “Services”).
We may modify this Privacy Policy from time to time. We will provide you with notice of any material changes to this Privacy Policy by publishing or communicating the changes through our Services or by other means so that you may review the changes before continuing to use our Services. Your continued use of the Services after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.
ACCOUNTABILITY AND OPENNESS / COMPLIANCE
Arrow is responsible for personal information under our control. We have established policies and procedures to effectively safeguard any confidential personal information that we collect, and to deal with complaints and inquiries. We are committed to maintaining the accuracy, confidentiality and security of your personal information, and we will ensure that you have access to information regarding the policies and procedures that we use to manage your personal information.
Arrow has designated a privacy officer (“Privacy Officer”) who is accountable for our compliance with this Privacy Policy, and for ensuring that information about our policies and practices relating to the management of personal information is easily accessible. All questions or concerns regarding this Privacy Policy and our compliance with it should be directed to the Privacy Officer in writing, and sent by email to social@arrow.ca.
CONSENT
Except as expressly provided in this Privacy Policy or as otherwise permitted by law, consent is required for the collection of personal information and the subsequent use or disclosure of that information. Consent may be expressed or implied. For consent to be meaningful, it must be informed consent and will only be valid if it is reasonable to expect that the individual understands the nature, purpose and consequences of the collection, use or disclosure of the personal information to which they are consenting. Typically, we will seek consent in advance or at the time of collection, and make reasonable efforts to ensure that you understand the purpose(s) for which we will use or disclose the information. In certain circumstances, we may seek consent regarding use or disclosure after the information has been collected, but before use, such as when we wish to use personal information already in our possession for a purpose that was not previously identified.
By voluntarily submitting your personal information or otherwise using the Services, you signify your agreement to the terms and conditions of this Privacy Policy and to our collection, use and disclosure of your personal information as set out herein. You may change or withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting the Privacy Officer in writing at one of the addresses listed above (see: Accountability and Openness / Compliance). In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.
INFORMATION YOU PROVIDE AND WE COLLECT
Arrow collects both information which is capable of identifying you as an individual (i.e. “personal information”), and information that is anonymous or aggregated such that it cannot be used to identify you. The types of information we collect include:
User submitted information: we may collect personal information from you when you request information or technical assistance from us, or register for or use the Services. Such information can include your name, mailing address, phone number, email, etc.
Technical and device information: we automatically collect certain non-identifying information from you when you access our Services. This information can include, among other things, IP addresses, the type of browser you are using (e.g., Internet Explorer, Safari, Chrome, etc.), the Services from which your visit originated, the operating system you are using (e.g., Windows 7/8/10, Windows XP, Mac OS, Android, iOS, etc.), the domain name of your Internet service provider (e.g., Shaw, Telus, Verizon, ComCast, etc.), the search terms you use on our Services, data that tracks the specific web pages you visit, and the duration of your visits. We collect such technical and device information for purposes of system administration, to report non-personal aggregate information to others, and to track the use of our Services. It is not our practice to link IP addresses (or other technical or device information) to anything personally identifiable; that is, the visitor’s session will be logged, but the visitor remains anonymous to us. However, we reserve the right to use IP addresses to identify a visitor when we feel it is necessary to enforce compliance with our Services’ rules or to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Services, or other users; or (d) in an emergency to protect the health and safety of our Services’ users or the general public.
Cookies/web beacons: “Cookies” are small text files from a website and/or mobile device that are stored on your hard drive and/or other storage device. These text files make using our Services more convenient by, among other things, saving your passwords and preferences for you. Cookies themselves do not typically contain any personally identifiable information. We may analyze the information derived from these cookies and other technological tools we employ (such as clear gifs/web beacons) and match this information with data provided by you or another party. We may provide our analysis and certain non-personal information to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information. Please note that advertisers that serve advertisements on our Services may also use their own cookies and other technological tools that are subject to the advertiser’s privacy policies, not this Privacy Policy. If you are concerned about the storage and use of cookies, you may be able to direct your Internet browser to notify you and seek approval whenever a cookie is being sent to your hard drive. You may also delete a cookie manually from your hard drive through your Internet browser or other programs. Please note, however, that some parts of our Services will not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.
Email Communications: If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social insurance/security numbers, or bank account information, to us by email. However, aside from our reply to such an email, it is not our standard practice to send you email unless: i) you request a particular service or sign up for a feature that involves email communications, ii) it relates to purchases you have made with us (e.g., product updates, customer support, etc.), iii) we are sending you information about our other products and services, or iv) you consented to being contacted by email for a particular purpose. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, agree to some communications but not others. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of any commercial emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
PURPOSES
We will identify the purposes for which we collect personal information before or at the time we request the information. We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. In addition to the purposes set out above (see: Information You Provide and We Collect), the purposes for which we collect personal information include:
- to enable you to access and use the Services;
- to process, track and communicate with you about usage of the Services;
- to establish, maintain and manage business relations with you so that we may provide you with the information, products or services that you request;
- internal business purposes, such as administering or improving the Services;
- to perform internal market research and conduct polls and surveys;
- to obtain feedback regarding the Services;
- to provide users with information and promotional materials regarding Arrow and our products and services;
- to protect us against error, fraud, theft or damage to our business or our property;
- to comply with any legal, accounting and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas or court orders; and
- any other reasonable purpose for which you provide consent.
Where personal information that has been collected is to be used for a purpose not previously identified, and for which consent cannot be reasonably implied, the new purpose will be identified and consent obtained prior to the use of that information for the new purpose unless otherwise permitted by law.
DISCLOSURE TO THIRD PARTIES
In the course of providing the Services to you, we may delegate our authority to collect, use or disclose your information to third party subcontractors. Third party subcontractors may include web hosts, payment processors, delivery and logistics providers and social network integrators. If we transfer any personal information to a third party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection while the information is being used by them.
We may disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request, request of a law enforcement agency, search warrant, subpoena or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to protect our business or assets, users of the Services, or the public.
We may also use and disclose your personal information without your knowledge or consent where necessary in connection with a proposed or completed business transaction, such as a sale of any or all of our business or assets. In each such case, we and the other part(ies) to the transaction or proposed transaction will enter into an agreement limiting the purposes for which the personal information may be used and disclosed, ensuring its protection by means appropriate to the sensitivity of the information, and providing for the return or destruction of the information if the transaction does not proceed, or if the transaction does proceed, to notify you within a reasonable time that your personal information has been disclosed.
SAFEGUARDS
We maintain reasonable security safeguards to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. We use user IDs, passwords and encryption technology, and restrict the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.
We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by using the Services and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.
ACCURACY / ACCESS
Arrow has a responsibility to ensure that all personal information contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date. You may make a request in writing for access to your personal information. Except as permitted or required by law, we will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed. You may have reasonable access to your personal information, and if you demonstrate the inaccuracy or incompleteness of personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, if your personal information changes, or if you wish to have your information removed from our files. All notices and requests should be in writing and sent to the Privacy Officer at the address listed above (see: Accountability and Openness / Compliance).
INTERNATIONAL TRANSFER AND STORAGE OF INFORMATION
You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of your country of residence, and therefore may be available to governmental authorities under lawful orders and laws applicable in such foreign jurisdictions. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of your country of residence.
THIRD PARTY CONTENT AND LINKS TO OTHER WEBSITES
The Services may contain optional links to third party Internet websites and services. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third party websites or services is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites or services. This Privacy Policy applies only to the Arrow Services, and we encourage you to review the privacy policies of any third parties when using their websites or services.
If you have any questions regarding our Privacy Policy, please contact us at the address below:
Arrow Group of Companies (Co)
Attn: Privacy Department
Email: social@arrow.ca
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