GALLEON FINE WINES INC. personal information protection policy

 

At Galleon Fine Wines Inc. (hereinafter “Galleon”, “we”, “us”, “our”), our mission is to passionately promote the best wines in the world to the best clients in Canada. Amongst its different online activities, Galleon operates this website (www.galleon.wine, www.galleon.vin, www.galleonwines.ca ) (the “Site”). This personal information protection policy (the “Policy”) explains what Personal Information we collect, use and disclose.

We invite you to read this Policy carefully before providing us with your personal information. If you have any questions about this Policy, do not hesitate to contact us by email at legal@galleonwines.ca or contact us at:

 

Attn: Privacy Officer
Galleon Fine Wines Inc.
1304, avenue Greene
Westmount, Quebec H3Z 2B1

 

By providing us with your Personal Information (as defined hereafter), you consent to the way in which we collect, use and disclose your Personal Information. If you do not consent to the collection, use and disclosure of your Personal Information in accordance with this Policy and/or the applicable laws, please do not provide any Personal Information to Galleon. Certain services may only be offered if you provide us with your Personal Information, and as such, Galleon may not be able to offer these services if you choose not to provide us with the required Personal Information.

In addition to this Policy, the use of the Site is subject to the Site Terms of Use (the “Site Terms”) and any order placed through the Site is governed by the Galleon Fine Wines Inc. Purchase Terms and Conditions[Note: add hyperlink] [PMG3] [MB4]  (the “Purchase Terms”). Please take some time to familiarize yourself with these agreements. You acknowledge that this Policy, the Site Terms and the Purchase Terms constitute one and the same document and that the subdivision into distinct pages is only to facilitate its consultation.

1    What type of Information we collect

Galleon collects information to operate our business and provide you with a great selection of products. We collect both Personal Information and Additional Information in support of these efforts.

1.1   Personal Information

The term “Personal Information” refers to any information about an identifiable individual or any information that allows an individual to be identified. Examples of such information include your name, your physical address, your IP address, your phone number, and other details such as your gender.

1.2   Additional Information

The term “Additional Information” refers to information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity. Some examples include your browser and operating system, time spent browsing the Site, and webpages visited. We collect and use this information to understand how you and our community as a whole use the Site and to tune, enhance and innovate the Site to reflect our community’s needs and preferences.

We do not consider Additional Information to be Personal Information. Regardless, if we link together Additional Information in a way that renders it individually identifiable, we will treat the combined information as Personal Information.

2    How we collect personal Information

2.1   Information You Provided to Us

When you register an account to purchase products from the Site, or when you complete a form on the Site or send us an email, you are providing us with Personal Information which we collect. Such information may, sometimes, include Personal Information such as:

2.1.1   Your name and last name;

2.1.2   Your username;

2.1.3   Your complete mailing address;

2.1.4   Your phone number;

Additionally, and on a voluntary basis, we ask that you provide the following information:

2.1.5   Your gender;

By giving us this information, you consent to your information being collected, used, processed, disclosed, and stored by us, only as described in our Site Terms and Policy.

2.2   Surveys and Promotions

When you take surveys and/or enter promotions, contests, and sweepstakes, we collect contact, demographic and eligibility information. We may sponsor surveys, contests, sweepstakes and other promotions ("Promotions") and we may request that you provide Personal Information, such as name, address, email address, telephone number and age and other information that may be appropriate in order to participate. If you win, we also may need to collect waivers and releases, depending on the prize.

We may also launch surveys that ask you to answer questions about a range of topics from personal information to brand and product preferences.

Promotions or surveys may also be run by a Galleon service provider or co-branded with one of our business partners. In such instances, Personal Information may be collected directly by and/or shared with Galleon, the service provider and/or business partner via print, website, mobile applications or other means. Each Promotion that treats your Personal Information in a way that differs from this Privacy Policy will state the privacy policy governing that collection of information in connection with that Promotion.

Additionally, with your consent we may share your Personal Information associated with a Promotion with our business partners that sponsored or were involved with that particular Promotion.

2.3   Payment Processing Information

Some financial information will be asked should you place an order through the Site. Credit card payments are handled by Stripe, an independent institution known for its secure Internet payment services. Once you confirm your order, you will be redirected to their environment. The information you will have to provide is your name, last name, email and street address, as well as your credit card information. This information will allow the purchase authorisation to proceed. This type of sensitive information, such as your credit card number, is encrypted and is protected during transmission.

This collection and protection of data is managed by Stripe. Galleon does not collect or receive your credit card information. Consequently, Galleon cannot be held liable in the event that some data was intercepted. You may visit the webpage https://stripe.com/ca/privacy to familiarize yourself with the personal data protection measures offered by Stripe.

2.4   Information Obtained From Your Use of the Site

Galleon uses cookies and other data collection tools, such as webserver logs to obtain information about how and when you use the Site. This information may include, but not be limited to, your IP address and location data, time, date and duration of each visits, browser used, referring web addresses, other communication data, searches conducted, pages visited.

Furthermore, Galleon may use a tool called “Google Analytics” to collect information about the use of this Site. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they visited prior to coming to this Site. We use the information we get from Google Analytics to, amongst other things, improve the Site. Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal Information.

Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You may opt out of Google Analytics tracking by following the information available on this page.

2.4.1   Cookies placed by the Site. The site will place the following cookies on your computer:

COOKIE NAME    COOKIE DESCRIPTION
   

CART

 

The association with your shopping cart.

CATEGORY_INFO

 

Stores the category info on the page, that allows to display pages more quickly.

COMPARE

 

The items that you have in the Compare Products list.

CURRENCY

 

Your preferred currency

CUSTOMER

 

An encrypted version of your customer id with the store.

CUSTOMER_AUTH

 

An indicator if you are currently logged into the store.

CUSTOMER_INFO

 

An encrypted version of the customer group you belong to.

CUSTOMER_SEGMENT_IDS

 

Stores the Customer Segment ID

EXTERNAL_NO_CACHE

 

A flag, which indicates whether caching is disabled or not.

FRONTEND

 

You session ID on the server.

GUEST-VIEW

 

Allows guests to edit their orders.

LAST_CATEGORY

 

The last category you visited.

LAST_PRODUCT

 

The most recent product you have viewed.

NEWMESSAGE

 

Indicates whether a new message has been received.

NO_CACHE

 

Indicates whether it is allowed to use cache.

PERSISTENT_SHOPPING_CART

 

A link to information about your cart and viewing history if you have asked the site.

POLL

 

The ID of any polls you have recently voted in.

POLLN

 

Information on what polls you have voted on.

RECENTLYCOMPARED

 

The items that you have recently compared.

STF

 

Information on products you have emailed to friends.

STORE

 

The store view or language you have selected.

USER_ALLOWED_SAVE_COOKIE

 

Indicates whether a customer allowed to use cookies.

VIEWED_PRODUCT_IDS

 

The products that you have recently viewed.

WISHLIST

 

An encrypted list of products added to your Wish list.

WISHLIST_CNT

 

The number of items in your Wish list.

 

2.5   Limiting Collection, Use and Disclosure

We do our best to limit the amount of Personal Information we collect to that necessary and appropriate for the identified purposes. We will not use or disclose your Personal Information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.

3    Why does GALLEON collects your personal information

3.1   Purposes

Galleon collects, uses and discloses Personal Information for the purposes identified at the time of collection, or as otherwise permitted or required by applicable laws, including the following purposes:

3.1.1   allowing for your subscription and use of the Website and its online purchase feature;

3.1.2   processing your orders, either directly by us or through one of our affiliates;

3.1.3   monitoring your order;

3.1.4   enabling you, upon request, to partake in our various promotional contests, our newsletter, our loyalty program; making it possible to deliver rewards, special offers and targeted benefits, to organize promotional events and to communicate with the winners of promotional contests, as well as to verify the identity of our loyalty program members. You can unsubscribe to any of these services at any moment through your account settings;

3.1.5   creating and maintaining our relationship with you;

3.1.6   recommending specific products tailored to your needs and preferences;

3.1.7   allowing you to voice your opinion about our products;

3.1.8   creating user profiles and statistics;

3.1.9   establishing strategic partnerships with businesses active in the food and beverage industry or facilitating the due diligence process in the context of a business acquisition;

3.1.10   developing and setting-up advertising campaigns; meeting the applicable legal requirements;

3.1.11   processing complaints; and/or

3.1.12   communicating with you, including for commercial purposes.

3.2   Purposes Not Identified Prior to Collection

When Personal Information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified and documented prior to use. Unless the new purpose is required by law, your consent will be requested before information can be used for that purpose.

4    Consent

4.1   Consent

To the extent possible, we will obtain consent to collect, use and disclose Personal Information directly from you. Galleon will not collect, use or disclose your Personal Information without your consent unless we are permitted or required to do so by applicable law.

4.2   Consent Obtained Prior to Collection

Generally, Galleon will seek consent for the use or disclosure of your Personal Information at or before the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Galleon wants to use information for a purpose not previously identified).

4.3   Withdrawal of Consent/Opting-Out

You may withdraw your consent to the use and disclosure of your Personal Information, or opt-out of certain uses and disclosures. To do that, please contact our Privacy Officer identified above.

5    How will GALLEON disclose your personal Information

Subject to this Policy, we pledge not to communicate or sell the Personal Information which we collect from you.

In the carrying on of Galleon’s business, Galleon’s authorized employees, mandataries or agents or any supplier into a contract with Galleon for work or services may have access to your Personal Information without your consent if such Personal Information is needed for the performance of their duties or the carrying out of their mandates or contracts. For example, we will disclose your Personal Information to our hosting provider.

If you consent to such communication, Galleon may communicate your Personal Information collected in compliance with the Policy to its affiliated companies or third parties for the purposes for which it was collected and meant to be used.

6    How will GALLEON store and secure your PERSONAL information

6.1   Duration

We store your personal data for as long as needed for the purposes previously mentioned. Once we no longer need it, we destroy and erase your Personal Information. Under the law, Galleon could be obligated to store, in full or in parts, the Personal Information it holds for a period of time longer than it would normally have chosen to. However, Galleon restricts the access to this Personal Information so that is be not used, except to meet these legal requirements.

6.2   Safeguards

Galleon will take reasonable security measures necessary to ensure the protection of the Personal Information collected, used, disclosed, or stored, given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored.

The methods of protection include:

  • physical measures (such as restricted access to offices);
  • organizational measures (such as security clearances); and
  • technological measures (such as the use of passwords).

Galleon will make its employees aware of the importance of maintaining the confidentiality of Personal Information, and care will be used in the disposal or destruction of Personal Information, to prevent unauthorized parties from gaining access to the information.

Personal Information that we collect is stored in a secured environment. The Site is secured with advanced SSL encryption for all data transmission.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Site; any transmission is at your own risk.

6.3   Transfer of Personal Information Outside of Canada

By disclosing your Personal Information to Galleon, you consent to your Personal Information being transferred outside of the jurisdiction of Canada.

6.4   Account Information

It is your responsibility to maintain the confidentiality of the password you use to access the sections of the Site that are protected by password. Consequently, you are responsible for all activity that will take place from your account or with your password.

Should you believe that the confidentiality of your account or password has been compromised in any way whatsoever, you must contact us immediately at:  technique@galleonwines.ca.

Galleon will be entitled to rely on the authority of anyone having access to an account or making use of a password and in no case can we be held liable for any fee, liability or damage resulting from: (i) an action or omission on our part with regards to this disposition; (ii) the compromise of an account or password’s confidentiality; and (iii) the unauthorized access to an account or unauthorized use of a password.

7    How can you access Your information

You will have a right to access, rectify and delete any Personal Information that we collect about you, as provided by this Policy.

To exercise these rights, you may contact us at the address mentioned at the beginning of this Policy. A reasonable charge may be required from your requesting of the transcription, reproduction or transmission of Personal Information.

In certain situations, Galleon may not be able to provide access to all the Personal Information it holds about you. Exceptions to the access requirement are meant to be limited and specific. The reasons for denying access will be provided to you upon request.

Galleon has put procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of Personal Information. To that effect, we will investigate all complaints we receive. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices.

8    Our social media presence

In order to create and maintain interactions with its clients, Galleon uses some platforms managed by third parties, including, without limiting the foregoing, Facebook, Twitter, Pinterest and Instragram. Applications and websites managed by third parties are web technologies that are not controlled or operated by Galleon exclusively. When you interact with Galleon on social media, you might disclose some personal information to Galleon or to a third party.

To this day, Galleon is active on two social media accounts, namely Facebook, Twitter, Pinterest and Instagram.

8.1   Facebook

On Galleon’s Facebook page, our employees publish posts that are susceptible to interest you. You may post comments as well, or click on the “like” option for posts published by our employees. If you post a comment or click on the “like” option, your personal information will be visible to Galleon’s employees and other visitors of the Facebook page. The extent of the personal information visible will depend on your own confidentiality parameters. You can avoid the display of your personal information by not creating an account, not posting comments and not clicking on the “like” option on our Facebook page. Apart from the Facebook notices that might be transmitted from time to time by email or notification, Galleon’s employees do not collect, use or disclose any information about the visitors who post comments or who “like” our Facebook page. Facebook collects and compiles non-identifiable personal data on the activities of Facebook pages. This information is protected by a password and is available only to Galleon’s employees and members of its communication team as well as to other designated employees who need this information to fulfill their tasks. Facebook’s data policy is available at: http://www.facebook.com/about/privacy/.

8.2   Twitter 

Galleon uses Twitter to send short messages, also called “Tweets”, to share information about Galleon with visitors and to answer questions and comments sent to Galleon through Twitter. Although some visitors may read Galleon’s Twitter thread without having subscribed thereto, visitors who wish to subscribe to (or follow) Galleon Twitter thread must create a Twitter account at www.twitter.com. To create an account, you will have to provide personal information, including a short biography, your location or a picture. Most of the information provided for the creation of a Twitter account is available to the public. Galleon’s employees supervise the number of subscribers and reply to comments and questions asked through Twitter, but these employees never appropriate personal information belonging to its Twitter followers. Apart from the Twitter notices that might be transmitted from time to time by email or notification, Galleon does not collect, store, disclose or share personal data about its Twitter followers. Twitter’s privacy policy is available at: http://twitter.com/privacy.

8.3   Pinterest 

On Galleon’s Pinterest account, our employees publish pictures that are susceptible to interest you. You may share this content, post comments on it or click on the “like” option for content published by our employees. If you share, comment or click on the “like” option, your personal information will be visible to Galleon’s employees and other visitors of the page. The extent of the personal information visible will depend on your own confidentiality parameters. You can avoid the display of your personal information by not creating an account, not sharing, not commenting and not clicking on the “like” option on our Pinterest pictures. Apart from the Pinterest notices that might be transmitted from time to time by email or notification, Galleon’s employees do not collect, use or disclose any information about the visitors who interact on our Pinterest pictures. Pinterest privacy policy is available at: https://about.pinterest.com/en/privacy-policy.

8.4   Instagram

On Galleon’s Instagram account, our employees publish pictures and other content that are susceptible to interest you. You may post comments on it or click on the “like” option for content published by our employees. If you comment or click on the “like” option, your personal information will be visible to Galleon’s employees and other visitors of the page. Please be advised that the colour of our products as depicted on our Instragm account is very dependent on the filters we use for each picture and is not necessarily indicative of the real colour of the wines offered. The extent of the personal information visible will depend on your own confidentiality parameters. You can avoid the display of your personal information by not creating an account, not commenting and not clicking on the “like” option on our Instragram pictures. Apart from the Pinterest notices that might be transmitted from time to time by email or notification, Galleon’s employees do not collect, use or disclose any information about the visitors who interact on our Instagram pictures. Instagram privacy policy is available at: https://www.instagram.com/legal/privacy/.

9    Changes to this Policy

Privacy laws are rapidly evolving and, as a result, this Policy may be changed by us from time to time at our discretion without any prior notice or liability to you or any other person. The collection, use and disclosure of your Personal Information by Galleon will be governed by the version of this Policy in effect at that time.