The e + o is committed to protecting the privacy of its customers and the confidentiality of their personal information.
This Customer Privacy Page describes the e + o’s protections of the privacy and confidentiality of the personal information it collects from you, as a customer. It also describes some of the ways the e + o collects personal information about you and how it uses, shares, and manages the personal information it collects. This page is not intended to describe every situation in which the e + o collects personal information. Other than as permitted or required by law, the purposes for the collection of personal information will be set out at the time of collection.
- What is “personal information”?
- What is the e + o’s statutory authority for collecting personal information?
- When does the e + o collect, use, and share personal information?
- Email and other communications
- Online registration
- Contests, competitions, co-branded participation, and promotions
- Market research
- Customer service
- Call recording
- Social Media
- Third parties acting on e + o’s behalf
- Data aggregation
- Cookies and tracking technology
- Third-party links
- How is personal information secured and protected?
- Accuracy and retention of personal information
- Contacting us
WHAT IS “PERSONAL INFORMATION”?
The term “personal information” means recorded information about an identifiable individual. To qualify as personal information, the information must be about the individual in a personal capacity. As a general rule, information about an individual in a professional, business or official capacity is not considered to be personal information. Examples of information that could be personal information include your name, address, gender, date of birth, email address, telephone number, credit card information, purchases, personal opinions, and social media user names. It may also, in certain situations, include information about your device, such as Internet Protocol (IP) addresses and browser information or browsing data such as the e + o Website pages you have visited.
WHAT IS THE e + o’S STATUTORY AUTHORITY FOR COLLECTING PERSONAL INFORMATION?
In most situations, personal information collected on or through interaction with e + o Websites or when you purchase or return products, is collected under the authority of the Liquor Control Act, R.S.O.1990, c.L.18, Sec. 3(1)(r).
WHEN DOES THE e + o COLLECT, USE, AND SHARE PERSONAL INFORMATION?
The e + o, and its service providers (third parties that we have engaged to help us conduct our business), may collect personal information from customers or visitors in person, over the telephone, by mail, by fax, or electronically when they interact with e + o Websites, e + o mobile applications, email, or through the use of our own or a third party’s technologies.
The e + o, and its service providers on behalf of the e + o, use personal information about you and your use of e + o Websites and mobile applications for various purposes, including the following:
- to process, verify, and deliver your orders;
- to better understand your product preferences;
- to improve the customer experience;
- to track and analyze trends and patterns;
- to administer the AIR MILES® Rewards Program including the awarding of reward miles to customers for purchases;
- to conduct and administer surveys, contests, draws and raffles;
- to conduct information and education programs such as tutored tastings and wine appreciation series;
- to comply with legal and regulatory requirements;
- to create Aggregate Data that does not allow you to be personally identified or contacted;
- to send communications, including promotional campaigns informing you about products and/or services;
- to tailor our online content or in-store offerings to you based on your interactions with us and your preferences;
Some examples of situations where we may collect and use your personal information are set out below.
The e + o may share personal information with its service providers as permitted by law, or with other third parties as permitted or required by law.
EMAIL AND OTHER COMMUNICATIONS:
From time to time, we may obtain your consent to send you email and other communications about products, services, promotions, surveys, customer feedback, events, or administrative functions. The e + o obtains consent for promotional email communications.
You can opt-out of receiving promotional email from us at any time by doing one of the following:
- If you originally signed up for email on one of our Websites please return to the email sign-up page on the Website, and click on the “unsubscribe” link, then enter your email address and click the “Submit” button. Please be sure to use the same email address as that which you used to sign-up, otherwise, it may not be possible to comply with your request.
- If you have received an email, you can follow the opt-out or “unsubscribe” instructions provided in your email.
When you request that your name be removed from our databases, it may not be possible to completely delete all your personal information due to technical and legal constraints. However, you will not continue to receive mail from the e + o once you request the removal of your name.
You do not have to register to visit e + o Websites. However, you may need to register and provide your personal information to be able to use some of the features offered through our online services. Your registration information is used to provide and administer the service you requested.
CONTESTS, COMPETITIONS, CO-BRANDED PARTICIPATION, AND PROMOTIONS:
When you enter a contest, competition or participate in a promotion, we may collect your personal information. We use this information to administer the contest, competition or promotion including contacting, announcing and promoting prize winners. At the time you enter the contest, competition or promotion, we may obtain your consent (i) to send you future promotional communications, and/or (ii) to disclose your personal information to a third party sponsor of the contest, competition or promotion, as specified at the time of collection of your personal information. We do not control the use, disclosure or security of your personal information by third party sponsors, and recommend that you review their privacy notices or statements.
We collect personal information for market research to enable customer-centric decision making. For example, we may ask you to provide postal code information or to participate in surveys or other customer research so that we can look at differences between geographic locations. Participation is voluntary. The information obtained through market research is used to create Aggregate Data that are in a non-personally identifiable form. We use this information to help us understand our customers, to enhance our product and service offerings, promotions and events, and/or to assist in the selection of store locations.
CUSTOMER SERVICE AND CUSTOMER FEEDBACK:
When you contact the e + o with a comment, question or complaint you may be asked for your name and contact information (such as address, email address and/or phone number), and details we need to help us answer your question or respond to your comment or complaint. If you submit this information online, your IP address and other device information is also automatically collected. We may also aggregate your comments, questions or complaints with those of other customers in order to look for trends to help us improve our service.
We may monitor and/or record telephone discussions when you call the e + o to enhance customer service, for training purposes and to confirm our discussions with you.
e + o uses social media accounts, such as Facebook, Twitter and Instagram (e + o Social Media Accounts) to share information and promote our products and services.
e + o Social Media Accounts are publicly accessible, and your posts, comments, and replies to, and mentions of, e + o may be publicly visible, depending on your privacy settings. Your privacy and the retention of information on social media accounts are governed by the privacy policies of the parties that operate these social networks. Some social media providers may allow you to control the information you make available to the e + o and others. Users should review and agree to privacy agreements and terms and conditions of the parties that operate these networks prior to participating. We do not have any control over such platforms, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked platforms collect, use, disclose, secure and otherwise treat your personal information.
THIRD PARTIES ACTING ON e + o’S BEHALF
We will not share personal information with third parties, or allow third parties to collect or use personal information, except for service providers who have agreed to comply with appropriate privacy standards, in order to perform services for the e + o (e.g., email deployment, direct mail, research, and surveys, credit card processing, customer feedback etc.). The e + o does not sell or rent our customer lists to outside agencies and/or our trade partners. Personal information that the e + o collects will not be used to place you on any mailing lists without your knowledge and agreement, or as otherwise permitted by law.
AGGREGATE DATA ABOUT INDIVIDUALS
The e + o, and service providers acting on the e + os behalf, may use personal information that you provide to the e + o, or that is collected electronically by automatic means when you interact with LCBO Websites and e + o mobile applications for the purposes of research, to inform operations, and for communications planning. This data may be aggregated by combining it with data pertaining to other individuals and “Aggregate Data” refers to personal information compiled and expressed in a summary format where no personal identifiers are included.
DATA COLLECTED BY COOKIES AND OTHER TRACKING TECHNOLOGIES
e + o Websites use both “first party” and “third party” cookies. First party cookies are created by the e + o directly, and third-party cookies are created by e + o service providers.
Web beacons are small image or script files that are downloaded when you visit a website or open an email. They capture activity and interactions on websites and mobile applications.
Cookies are used to improve the content and usability of e + o Websites and in combination with web beacons help us understand what actions you take on e + o Websites and mobile applications and ensure they work correctly. It is not used for marketing or advertising purposes.
You can set your Internet browser to refuse to accept cookies and web beacons from e + o websites. Some browsers can be set to accept all cookies, reject all cookies, or notify you when you receive cookies. If you choose to modify your browser, some pages or features of the Website may not function properly.
e + o uses third party web analytics tools to analyze the information generated through the use of third-party cookies to look at Aggregate Data that is used for operational purposes.
HOW IS PERSONAL INFORMATION SECURED AND PROTECTED?
The e + o and its service providers maintain your personal information in a combination of paper and electronic files. e + o and its service providers employ reasonable technical, physical, and administrative security measures to protect your personal information. However, it is impossible to guarantee security since “perfect security” does not exist. Consequently, the e + o does not represent, warrant, covenant, or guarantee the complete security of the personal information it or its service providers collect. As well, in some cases, information is stored outside of Canada and in exceptional circumstances may be available to government authorities under lawful orders and laws applicable in the relevant jurisdictions.
ACCURACY AND RETENTION OF PERSONAL INFORMATION
The e + o will make reasonable efforts to ensure the accuracy of your personal information when you request it as long as it does not compromise e + o’s privacy or security interests.
The e + o will keep your personal information for as long as it remains necessary for the identified purposes or as required by law, or in accordance with our retention schedules, which may extend beyond the termination of our relationship with you. The e + o reserves the right to maintain personal information records for both active and inactive (i.e. unsubscribed) customers.
If you have any questions concerning the e + o Customer Privacy Page or wish to file an access or correction request, please contact the Senior FOI & Privacy Advisor at:
E-mail: [email protected]