Privacy Policy 

 

Effective date: June 14, 2023

 

Introduction 

Southern Glazer's Wine and Spirits of Canada, LLC (“SGWS”, “our”, “us” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy. The purpose of this Canadian privacy policy (the “policy”) is to explain how and for what purposes we collect, use, share or otherwise process your personal information and how we safeguard the confidentiality of your personal information, whenever you access  our  website at ca.southernglazers.com/en (the “website”), including when you contact us through social media, email, text, collectively with the website, the “Services”). This Privacy Policy also describes the rights you have with respect to your personal information.

 

Note that this policy does not apply to the personal information we collect: 

  • About you offline (e.g., when you visit our offices) or through any other means than through the Services, such as when you access any other website operated by the SGWS or any third party; or 
  • Whenever you interact with any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. 

 

Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. This policy may change from time to time (see Changes to Our Privacy Policy for more information).  

 

1.       Personal Information

 

In this policy, “personal information” generally means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, postal address, e-mail address, telephone number, or any other contact details. It may also include other types of more technical information, but only when this information can identify you as an individual, such as your IP address, the equipment you use to access our Services and details on your usage of our Services. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be personal information, if it is, at all times, reasonably foreseeable in the circumstances that this information irreversibly no longer allows the individual to be identified directly or indirectly.

Generally, depending on where you reside, “personal information” does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession such as the individual’s name, position name or title, work address, work telephone number, or work email address.

 

2.       Information We Collect About You and How We Collect It

 

Directly from you

We collect personal information from you when you provide the information directly to us, such as when you contact us or when enter your personal information on our website to create an account. Examples of information we collect from you and use are:

  • Information you provide when creating an account to use our Services or subscribe to our Services: such as your name, email address and password.
  • Information you provide us when contacting us or responding to a survey: such as your name and contact information if you contact use by phone, email, or SMS, and any information you may share with us when responding to a survey that we might ask you to complete for research purposes.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., your social insurance number, health information, biometrics or genetic characteristics, or criminal background information) on or through the Services or otherwise to us. 

 

Automatically

As you navigate through and interact with our Services, we may use automatic data collection technologies such as cookies and web beacons to collect certain information about your equipment, browsing actions, and patterns, including: 

  • Information on your use of our Services: such as traffic data, location data, logs, clickstream data, usage data, and other communication data and the resources that you access, download and use on the Services. 
  • Information on the equipment you use to access our Services: such as information about your computer and internet connection, including your IP address, operating system, and browser type. We may also derive your approximate location from your IP address. 

 

The information we collect automatically helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Services according to your individual interests.
  • Speed up your searches.
  • Recognize you or your company when you return to our Services.

3.       Cookies and similar Technologies

 

The technologies we use for this automatic data collection may include: 

 

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer that allows us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data.  We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services.  We may also use cookies or other technologies in online advertising to track responses to our ads. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services. 
  • Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.  
  • Pixel tags and other similar technologies.  Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.   
  • Analytics. We use Google Analytics or Adobe Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other Website, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and Adobe’s practices by going to https://www.adobe.com/ca/privacy/policy.html. You may exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout and may exercise the opt-out provided by Adobe by visiting https://www.adobe.com/ca/privacy/opt-out.html#communication. 

 

For information about managing your privacy and security settings for cookies, see Choices About How We Use and Share Your Information.

 

4.       Third-Party Online Advertising

 

Some content or applications, including advertisements, on our Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Website and other online services. They may use this information to provide you or your company with interest-based (behavioral) advertising or other targeted content. 

 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Share Your Information.   

 

5.       How We Use Your Information 

We may use your personal information for the following purposes:

·         Providing our services. We use personal information as necessary to provide and deliver our services to you or your company, including by tailoring our Services to your interests. For instance, we may need to use your personal information to manage our business relationship to deliver a product of service.

·         Communicating with you. If you contact us with a question or inquiry, we may use your personal information to respond to you. We may also communicate with you for business development purposes, to promote our services and offers, and to notify you about changes to our Services or any products or services we offer or provide through them.

·         Managing our business. We use your personal information for several reasons in connection with our business operations, which may include carrying out our obligations and enforcing our rights arising from any contracts entered into between you or your company and SGWS, including for billing and payment collection purposes.

·         Managing our websites. We use information we collect from websites visitors to manage and improve our websites (see Cookies and similar technologies for more information).

·         For other purposes as permitted or required by law. For example, we may use the information we collect to protect the security of that information and our websites or to comply with a legal requirement, if necessary.

We may also request your consent to use your personal information for other specific purposes. For more information, see Choices About How We Use and Share Your Information. 

 

6.       How We Share your Personal Information  

 

We may share your personal information as follows:

·         With our affiliates and subsidiaries. We may share personal information with our affiliated and subsidiary companies for the purposes described in this policy, in particular to comply with applicable laws, regulations and requirements, ensure that your information is consistent, accurate and up to date, and increase the quality and relevance of our Services.

·         In the context of the sale or transfer of our business or other transaction. We may decide to sell or transfer all or part of our business to a third party, merge with another entity, secure our assets or proceed with any other financing or other strategic capital transactions (including insolvency or bankruptcy proceedings), restructuring, share sale or other change in corporate control. We may share your personal information when required for the purposes of such a transaction.

·         Other permitted reasons. We may share your personal information when permitted or required by applicable law. This may be the case, for instance, if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety or that of our users, or others; or to detect or counter fraud and credit risk management.

We may also share information that does not identify, such as information that has been aggregated or anonymized in such a manner that it no longer reveals your identity. 

 

7.       Your Choices About How We Use and Share Your Information

 

We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information: 

  • Cookies and Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you do not want Flash cookies stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel and instructions found on the Global Storage Settings Panel. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.  
  • Third Party Online Advertising. To learn how to opt out of third-party online advertising in desktop and mobile browsers on the particular device on which you are accessing policy, please visit http://optout.aboutads.info/# / and http://optout.networkadvertising.org/#/ .  You may download the AppChoices app at www.aboutads.info/appchoices  to opt out in mobile apps.  
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for third-party promotional purposes, you can opt out by sending us an email stating your request to contactus@sgws.com.
  • Promotional Offers from SGWS. If you do not wish to have your contact information used to receive promotional materials from SGWS to promote its own or third parties' products or services, you can opt out by checking the relevant box located on the form on which we collect your data (the registration form) when you create an account with us or subscribe to our Services, or at any other time by sending us an email stating your request to contactus@sgws.com. If we have sent you a promotional commercial electronic message, you may send us a return message asking to be omitted from future email distributions or follow instructions in the email to unsubscribe.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by sending us an email stating your request to contactus@sgws.com.

8.       Website Links to Third-Party Websites

 

This policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.  

 

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, Adobe, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with the Apps. To the extent you opt-in for SMS messages such SMS opt-in will not be shared with any third parties.

 

9.        Retention of Personal Information

 

SGWS will retain your personal information for as long as necessary to provide our services to you, to manage our business operations, and to comply with our legal and regulatory obligations. Once no longer required, your personal information will be securely destroyed or anonymized (so that it is, at all times, reasonably foreseeable in the circumstances that the information irreversibly no longer identifies you directly or indirectly).

 

10.   Your Individual Rights

 

SGWS respects your right to access your personal information and to request its rectification if it is inaccurate, incomplete or equivocal, subject to any applicable legal restrictions.

 

Depending on the jurisdiction in which you reside, you may also have the right to obtain more information about SGWS’ processing of your personal information, including the categories of individuals who have access to your personal information within our organization and the applicable retention period for your information. 

 

If you require access to your personal information please first check any account profiles that you have with us, such as your account profile. If you are unable to locate the personal information you require access to, or you would like to access or correct your personal information, or if you have any questions about the collection, use and disclosure of your personal information that are not answered by this policy, please contact us using the information in How to Contact Us.  

 

Note that while you can withdraw your consent to SGW’s processing of your personal information at any time, if you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users of our Services. Proper access and use of information provided on the Services, including User Contributions, is governed by our Terms of Use. 

 

11.    Security of your Personal Information and Data Governance

 

We use administrative, physical, and technical safeguarding measures to maintain the security of your personal information, appropriate to the sensitivity and amount of personal information SGWS’ control, to the purposes for which it is used and the format in which it is stored.

 

We have also implemented a comprehensive set of policies and practices to protect your personal information. These measures take into account the volume, sensitivity, intended use, and format of the information, and generally include the following:

·         A privacy governance program comprised of policies and procedures regarding the protection of personal information through its lifecycle and which defines the roles and responsibilities of SGWS’ personnel regarding the handling of personal information.

·         A designated Privacy Officer accountable for SGWS’ compliance with applicable privacy laws.

·         Employee privacy and data security training.

·         Procedures for receiving, investigating and responding to complaints or inquiries regarding SGWS’ information handling practices.

·         Contractual provisions and other measures to require our service providers with whom we share personal information to maintain adequate privacy protections and standards. 

 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services. 

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. 

 

12.   Where We Store Your Personal Information

 

We may use service providers who process or store information in various regions of Canada, outside of Canada, including in the United States or other jurisdictions where we may have operations. As such, personal information may be subject to foreign laws and may be accessible by foreign governments, courts, law enforcement and regulatory agencies.

 

13.   Children Under the Age of 16

 

The Services are not intended for persons under the legal drinking age (18 years in the provinces of Manitoba and Quebec, Alberta and Manitoba and 19 years in all other Canadian provinces and territories). No one under age 16 may provide any personal information to or on the Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Services or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at: contactus@sgws.com

 

14.   Changes to Our Privacy Policy

 

We may make changes to this policy from time to time. Any changes we make will be effective when we post the revised policy on our websites. If we make any significant changes to the policy, we will post a notice on our websites or contact you to inform you when required by law. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements that may apply. The “Effective Date” at the top of this policy indicates when it was last updated.

 

15.   How to Contact Us  

 

To ask questions or comment about this privacy policy and our privacy practices or to exercise your privacy rights, please contact our privacy officer at contactus@sgws.com.