Last Updated January 12, 2021
The purpose of this Policy is to describe the information collection, use, and dissemination practices of the Company, its parent, subsidiaries and registered d/b/a companies (collectively referred herein after as “the Company”) and all related websites owned or registered to the Company and applies to the Company’s collection, use, storage and disclosure of information by the Company on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various Third Party websites, and (c) to the Company’s other information collection, including the acquisition of customer information from third parties. The Company is not responsible for the information collection or privacy practices of third party websites or applications.
By providing us with your data on our Website or in the course of using our services, you consent to the transfer of your Personal Data and Sensitive Personal Data, and any other data we acquire about you from third-party service providers.
Information Collection, Use, and Dissemination practices
This policy applies to the Company’s collection, use, storage and disclosure of information by the Company on its, (a) Websites, (b) on various third party websites, and (c) to the Company’s other information collection, including the transfer of opt-in customer lists from third parties, or the use of customer opt-in lists from third parties. The Company is not responsible for the information collection or privacy practices of third party websites or applications.
Collection of Information
1.1 User Direct Information:
Each time you provide transmit information via the Website, the Company may obtain and collect personally identifiable information provided by you, including, but not limited to, your name, email address, business address, position, and phone number. You may also provide us with information that, when combined with personally identifiable information, provides us with a better idea of who you are, referred to as “data”. If you choose to access our website, use our services or purchase our products, we may require you to provide data as indicated on the forms throughout the site.
1.2 Cookies, Web Beacons, and Other Info Collected Using Technology:
The Company currently uses cookie and web beacon technology to associate certain Internet-related information about you with information about you in its database. Additionally, the Company may use other new and evolving sources of information in the future.
(b) Web Beacons
A web beacon is a programming code that can be used to display an image on a web page, but can also be used to transfer your unique user identification to a database and associate you with previously acquired information about an individual in a database. This allows the Company to track certain websites you visit. Web beacons are used to track online behavioral habits for marketing purposes to determine products or services you may be interested in. In addition to using web beacons on web pages, the Company also uses web beacons in email messages sent to individuals listed in the Company’s database.
(c) IP Addresses
The Company automatically tracks certain information based upon your behavior on the site. We may use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on the site or not), which URL you next go to (whether this URL is on the site or not), your computer browser information, and your IP address. Your Internet Protocol (“IP”) is a unique Internet “address” which is assigned to you by your Internet Service Provider (“ISP”). For local area network (“LAN”), DSL, or cable modem users, an IP address may be permanently assigned to a particular computer. IP addresses are automatically logged by Web servers, collecting information about a user’s traffic patterns. While the IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual using the Web. Your IP address can, however, reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages.
(d) Computer Profiles
(e) Data Analysis
Data Analysis technology may be employed from time to time if used by a Client of the Company.
(f) New Technology
The use of technology on the Internet, including cookies and web beacons, is rapidly developing. As a result, the Company strongly encourages individuals to revisit this policy for any updates regarding its use of new technology.
1.3 No Information Collected from Children
The Company will never knowingly collect any data about children under the age of 13. If the Company obtains actual knowledge that it has collected data about a child under the age of 13, that information will be immediately deleted from its database. Because it does not collect such information, the Company has no such information to use or to disclose to third parties. The Company has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
1.4 Credit Card Information
The Company may, in certain instances, collect credit card numbers and related information when a customer places an order from the Company. When the credit card information is submitted to the Company, such information is encrypted and is protected with SSL encryption software. The Company will use the credit card information for purposes of processing and completing the purchase transaction, and the credit card information will be disclosed to third parties only as necessary to complete the purchase transaction.
Use of Individual Information
2.1 General Use
The following paragraphs in Section 2 describe how theCompany currently uses data collected from or about you (“your data”), but the Company may change or broaden its use at any time. As noted below, the Company may update this policy from time to time. The Company may use your data to provide promotional offers to you by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
2.2 Email and Unsubscribe Policy
The Company uses your data to provide promotional offers by email to individuals. The Company may maintain separate email lists for different purposes. If email recipients wish to stop receiving email, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all of the Company’s email lists, a person must send an email to email@example.com.
The Company’s unsubscribe process impacts only the future delivery of electronic mailings disseminated by the Company on its own behalf. You may still receive electronic mailings sent on behalf of Third Parties and your data may still be shared with Third Parties for use in offline marketing and data appends, including email appends.
You should also note that unsubscribing from the Company’s electronic mailings will not automatically unsubscribe the subscriber’s information from any Third Party business associates and licensees of the data. Since Third Party associates and licensee partners maintain separate databases from the Company, and you will need to unsubscribe from each source individually, if desired. This allows you the freedom to pick and choose which subscriptions to maintain and which to discontinue.
2.3 Content of Email Messages
In certain commercial email messages sent by the Company, an Advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to the Company. The “Subject:” line of the Company email messages will usually contain a line provided from the Advertiser to the Company.
2.4 Solicited Email
The Company only sends email to individuals who have agreed on the Websites to receive email from the Company or to individuals who have agreed on a Third Party website to receive email from Third Parties. As such, the Company does not send unsolicited email messages. As a result, United States statutes requiring certain formatting for unsolicited email are not applicable to the Company ‘s email messages.
The Company may use your data to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones. By registering and using this Site, You acknowledge that the processing of your data may involve the transfer of such Individual information from within or outside the European Economic Area (“EEA”) to countries within or outside the EEA whose data protection regulation may not be as stringent as that within the European Union. We may use individual information to provide the services you’ve requested, including services that display customized content and advertising.
2.6 Wireless Addresses
If the e-mail address you provide to the Company is a wireless e-mail address, you agree to receive messages at such address from the Company or its business associates (unless and until you have elected not to receive such messages by following the instructions in the unsubscribe portion of this policy). You understand that your wireless carrier’s standard rates apply to these messages. You represent that you are the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges.
2.7 Short Message Service
You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. We may also access the content of your account and wireless account with your carrier for the purpose of identifying and resolving technical problems and service-related complaints.
You may remove your data from the Company’s database. If you remove your data from the Company’s database it will no longer be used by the the Company for secondary purposes, disclosed to third parties, or used by the Company or third parties to send promotional correspondence to you. You may remove your data by sending your request in writing via email to firstname.lastname@example.org or by sending “STOP”, “END”, “QUIT” to the SMS text message you have received.
2.8 Storage of Your Data
The Company stores your data in a database on its computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under the Company’s control. Notwithstanding such measures, the Company cannot guarantee that its security measures will prevent its computers from being illegally accessed, and the Individual Information on them stolen or altered.
Use of Your Data
The Company will use your data for any marketing and survey purpose on behalf of the Company and its affiliates and subsidiaries to send information to you about additional goods or services that may be of interest to you.
3.2 Service Providers
We may use third parties to help operate our Web Site and deliver products and services, and may share your data with our affiliates, service providers and other third parties that provide products or services for or through this Website or for our business (such as website or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf). Unless otherwise stated, these companies do not have any right to use your data that we provide to them beyond what is necessary for them to assist us. When you conduct e-commerce with one of the e-commerce affiliates or service providers to which the Website may be linked, certain data such as your e-mail and home address may be collected by the service provider’s server and made available to us.
3.3 Aggregate Statistics
We may disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, our Website and e-mails to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.
3.4 Complying with Legal Process
The Company will use or disclose your data in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise our legal rights or defend against legal claims or in the event you violate or breach an agreement with the Company. The Company will use and disclose your data if we believe you will harm the property or rights of the Company, its owners, or those of the Company’s other customers. Finally, we will use or disclose your data if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Company’s acceptable use policy, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.
3.5 Third Parties
The Company may provide your data to third parties with whom they have a business relationship for the purposes of securing the services and products you have requested or provide you with additional marketing materials from which you may choose additional products or services.
Privacy Practices of Third Parties
4.1 Advertiser cookies and web beacons
Advertising agencies, advertising networks, and other companies who place advertisements on the websites and on the internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. The Company does not control the use of such technology and the Company has no responsibility for the use of such technology to gather information about you.
The websites and email messages sometimes contain hypertext links to the websites of third parties. The Company is not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by third parties. Such links are provided for your convenience and reference only. The Company does not operate or control in any respect any information, software, products or services available on such third party websites. The inclusion of a link to a website does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
The Company further reserves the right to disclose, transfer or sell your data to companies who are affiliated with the Company in the Company’s sole discretion. If the Company changes ownership through an acquisition, merger, sale or other change of business status, it reserves the right to transfer or assign the right to use your Data collected from the Website.
How You can access Your Data
If your data changes, or if you would no longer like us to contact you, you may correct, update, or request deletion by emailing us at email@example.com.
We will retain your data for as long as needed to provide you services. We may also retain and use your data as necessary to comply with our legal and audit obligations, resolve reported and potential disputes, and enforce our agreements. If you wish to request that we no longer use your data to provide you services, please contact us at firstname.lastname@example.org. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing all such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. All requests are also subject to the next section below (“Your Choices About Collection and Use of Your data”),
We also maintain an information security program that limits storage of data to what is needed to fulfil our reasonable business, legal and audit requirements.
Your Choices About Collection and Use of Your Data
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our website because such information may be required in order for you to apply for or obtain products or services
If you receive e-mail messages or newsletters from us, you will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to 10 business days for us to fully process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as requests for additional information, confirmations, service updates or announcements, administrative notices and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of commercial e-mail communications will only affect future activities or communications from us. If we have already provided your data to a third party before you have changed your preferences or updated your data, you may have to change your preferences directly with that third party.
How We Protect Your Data
We take appropriate security measures (including physical, electronic, and procedural measures) to help safeguard your data from unauthorized access and disclosure. We follow generally accepted industry standards to protect the data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Foreign use of the Website
To the extent that you are accessing the Website while domiciled outside of the United States, you acknowledge that the Data you are providing the Company is collected and stored in the United States and therefore consent to the transfer of information to and storage of the information outside of your domiciled country and in the United States.
California User Consumer Rights
Under the California Consumer Privacy Act (“CCPA”) signed into law June 28, 2018 and entering into effect Jan. 1, 2020, California residents have certain rights and privileges. You can exercise any of the following CCPA rights by notifying us as described below:
- Disclosure Request: Upon request and when possible, we will disclose the categories and specific pieces of data we have collected about you. Additionally, you may also obtain the categories of information about you that we have sold, the categories of third parties to whom the information was sold, and the categories of data that we disclosed about you for a business purpose. You may submit these requests by calling 1-800-975-0515. When such a request cannot be honored, we will advise you accordingly.
- Deletion: If you should wish to cease use of our Website and related products and services and have your personal data deleted from our Website, then you may submit a request by calling 1-800-975-0515. Upon receipt of a verifiable request for deletion, we will confirm receipt and will confirm once your personal data has been deleted.
- Do Not “Sell”: Under CCPA, you have the right, at any time, to direct a business that sells data about the consumer to third parties not to sell the consumer’s data. Certain transfers of data to our affiliates may be deemed a “Sale” under CCPA. If you wish to exercise your right to opt out, you may submit a request by calling 1-800-975-0515. Upon receipt of a verifiable opt out request, we will confirm receipt and limit the transfers of your data accordingly.
- Right to Sue for Security Breaches: You also have the right to sue in the event your non-encrypted or non-redacted data, is subject to an unauthorized access and exfiltration, theft, or disclosure as a result of the our violation of the duty to implement and maintain reasonable security procedures and practices. Prior to exercising this right, you must provide us with 30 days’ written notice by emailing us at email@example.com and providing us with an opportunity fix this violation.
We reserve the right to ask for information verifying your identity and residency prior to disclosing any information to you or acting on your request. Should we ask for verification, the information you provide to verify your identity and residency will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete. We strive to respond to your request within 45 days of receiving a verifiable consumer request however, we reserve the right to respond within 90 days when reasonably necessary.
Under California’s “Shine the Light” law, California residents who provide PERSONAL IDENTIFYING INFORMATION in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the Individual PERSONAL IDENTIFYING INFORMATION we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of Individual PERSONAL IDENTIFYING INFORMATION and the names and addresses of those businesses with which we shared Individual PERSONAL IDENTIFYING INFORMATION for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities). To obtain this information from us, please contact us at the following email address: firstname.lastname@example.org and write “Request for California Privacy PERSONAL IDENTIFYING INFORMATION” for the subject of your message. We will send you a reply e–mail within 30 days containing the requested information once we confirm your request. Not all information sharing is covered by the “Shine the Light” requirements and only that information which is covered will be included in our response.
Do not Track Disclosures
Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Our Website do not currently respond to these “do-not-track” signals.
Your data, including PERSONAL IDENTIFYING INFORMATION, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note we transfer your data, including PERSONAL IDENTIFYING INFORMATION, to the United States and process it there. Your submission of information to us represents your consent to that transfer. Please note the EU has not adopted an adequacy decision with respect to data transfers to the United States, nor are we a participant in the EU-US Privacy Shield; however, we value your privacy and protect your data using reasonable information security practices.
Third Party sites
From time to time, the Website may link you to other sites or applications (“Linked Sites”) that are not owned by us. We do not control the collection or use of any information, including PERSONAL IDENTIFYING INFORMATION, which occurs during your visit to the Linked Sites. Further, we make no representations about the privacy policies or practices of the Linked Sites, and the Company is not responsible for the privacy practices of these Linked Sites.
Be careful of disclosing any of your PERSONAL IDENTIFYING INFORMATION when leaving our Website. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that collects PERSONAL IDENTIFYING INFORMATION.
In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to email@example.com. For more information about protecting your privacy, you may wish to visit: http://www.ftc.gov
If you have questions about this policy, please contact us firstname.lastname@example.org
If you believe that Our Website are not following our stated information policy, you may contact us at the above address.
PHMG (Canada) Inc., its parent, subsidiaries and affiliates (“PHMG”, “we”, “us”) respect your privacy.
What Personal Information We Collect
Personal information is information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person (“Personal Information”). Personal information does not include business contact information, including your name, title, or business contact information. We collect Personal Information when you voluntarily provide it through our Website or when you provide it to us through other means, including but not limited to: email, telephone, mail; or other correspondence; or register for our Services.
How We Collect Information Through Technological Means
When you visit our Website and/or use our Services, we may collect information that is automatically sent to us by your web browser. This information may include your domain name and your IP address. We may also collect other information, such as the type of browser you use, which pages you view, and the files you request.
We use this information to better understand how our Website and Services are used and to improve our Website and Services to better meet your needs. The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this.
We also collect information that is submitted by you. This incudes information that you provide by filling in forms on our Website, such as information provided at the time of registering to use our Website or subscribing to our Services, posting material, or requesting further services. We may also collect information when you report a problem with our Website, search queries on our Website, or otherwise provide information to us. We further collect information from records and copies of your correspondence (including email addresses), if you contact us.
“Cookies” are text files placed on your computer, to help the website analyze how users use the websites. We may use “cookies” and other similar devices on our Website and Services to enhance functionality. These devices may track information which includes, but is not limited to:
(i) IP address;
(ii) how the website is navigated;
(iii) the type of web browser and operating system used;
(iv) the content accessed; and
(v) the pages of the Website visited.
If you wish to disable cookies, refer to your browser help menu to learn how. If you disable cookies, you may be unable to access some features related to the provision of our Website and Services.
Age of Majority
Our Website is not intended for persons under the age of majority. No one under such age may provide any information to or on the Website. We do not knowingly collect personal information from children or persons under the age of majority. If you are under the age of majority, do not use or provide any information on this Website or Services, including your name, address, telephone number, email address, or any screen name or user name you may use.
How We Use and Discloses Personal Information
(i) to present our Website and/or Services and its contents to you and to improve such;
(ii) to provide you with information, products, or services that you request from us;
(iii) meet legal and regulatory requirements; (iv) track and analyze trends and patterns;
(v) to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information to the Website and/or Services;
(vi) to respond to questions, comments, surveys, requests, job applications, or complaints that you submit to PHMG;
(vii) create aggregate information that does not allow you to be personally identified; (viii) to improve our customer relationships and experiences; and/or to communicate information, such as promotions, newsletters, surveys, contests, etc. if you have consented to receive such from PHMG.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may also disclosure Personal Information to: (i) our subsidiaries and affiliates; (ii) in accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PHMG’s assets; (iii) To fulfill the purpose for which you provide it; and (iv) with your consent.
We may also disclose your personal information:
(i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
(ii) to enforce or apply our Terms and other agreements;
(iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PHMG, our customers, or others.
Where we disclose Personal Information to third parties that perform services on our behalf, we will require those third parties to use such information solely for the purposes of providing services to us and to have appropriate safeguards for the protection of that Personal Information. You may separately agree to provide your Personal Information to third parties that provide content and/or offerings to our Website and/or users. If you agree to provide such information to these third parties, then your Personal Information will be subject to their privacy policies in addition to our own.
We may disclose your Personal Information to a third party or parties where you consent to such disclosure or the disclosure is required by law. Some or all of the Personal Information we collect may be stored or processed in jurisdictions outside of Canada, including the United States. As a result, this information may be subject to access requests and legal requirements from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
We reserve the right to transfer Personal Information in the event that we merge with or are acquired by a third party. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.
Transferring Your Personal Information
We may transfer Personal Information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business. To the extent possible, we will obligate such businesses to use this information only for the purposes for which we disclose it to them and to process the Personal Information with the same standards set out in this policy.
We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country.
By submitting your Personal Information or engaging with the Website and/or Services, you consent to this transfer, storage, or processing.
How We Protect Personal Information
We protect your Personal Information by maintaining physical, organizational and technological safeguards appropriate to the sensitivity of such Personal Information. Personal Information may only be accessed by persons within or under contract with our organization and who require such access. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. 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 Website.
We retain Personal Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements. We destroy Personal Information when it is no longer needed.
The Website and Services may provide links to other third party content. Even if the third party is affiliated with PHMG, through a business partnership or otherwise, PHMG is not responsible for the privacy policies or practices or the content of such external links. We do not assume responsibility for the accuracy or appropriateness of the content contained on those websites and/or other services. You enter those sites at your own risk. A link to the same should not be construed to mean that we are affiliated or associated in any way or that we endorse or recommend those websites and/or services. These links are provided to you for convenience purposes only and you access them at your own risk.
Access and Rectification
You have a right to access to your Personal Information and to request a correction to it if you believe it is inaccurate. We will provide you with access to your Personal Information that is in our possession, subject to certain exceptions, including information that is referenced to another individual’s personal information that we cannot sever, or information subject to legal restrictions that may prevent us from fulfilling your request. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below.
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the contact information below. Please note that if you withdraw your consent we may not be able to provide you with use or access to our Website or Services.
How to Contact Us