LAST REVISED:  03-23-1815
SIMON PURE MARKETING INC. PRIVACY STATEMENT
Toronto, ON, Canada

Simon Pure Marketing Inc.(“[company]”,“us”or“we”) is concerned about online privacy issues and wants you to be familiar with how we collect, use and disclose any personal information that individually identifies you (e.g. your name, address, phone number, e-mail address).  Personal information means any information about an identifiable individual, but does not include the name or business contact information of an employee of an organization. This Privacy PolicyPrivacy Statementexplains our online information practices and the choices you, as a visitor to this website, can make about the collection and use of your personal information. We will only collect, use and disclose your personal information in accordance with this Privacy PolicyPrivacy Statement.

ThisPrivacy PolicyPrivacy Statementis incorporated into and forms part of our Terms of Use, which outline the terms and conditions you agree to when accessing and using this website. By accessing and using this website, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Privacy PolicyPrivacy Statement.

COMMITMENT: ADHERING TO THE 10 PRIVACY PRINCIPLES

In Canada, “Fair Information Practices” regarding your Personal Information are reflected in a series of 10 Privacy Principles developed by the Canadian Standards Association and incorporated into Canadian federal privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”).  Simon Pure Marketing Inc.adheres to the 10 Privacy Principles as follows:

Principle 1 — Accountability

  • Simon Pure Marketing Inc.is responsible for Personal Information under its control and has designated a Privacy Officer who is accountable for Simon Pure Marketing Inc.’s compliance with this Privacy Statement and the applicable privacy legislation for Canada and its provinces.

Principle 2 — Identifying the Purposes for collection of Personal Information

  • Simon Pure Marketing Inc.will identify the purposes for which your Personal Information is collected at or before the time the Personal Information is collected. Some of the identified purposes for which Simon Pure Marketing Inc.collects, uses, and discloses your Personal Information are described below in this Privacy Statement. If we intend to collect, use or disclose your Personal Information for additional purposes, we will seek your consent.

Principle 3 — Consent for Collection, Use of Disclosure of Personal Information

  • Simon Pure Marketing Inc.will obtain your informed consent for the collection, use, or disclosure of your Personal Information, except as permitted by law.

Principle 4 — Limiting Collection of Personal Information

  • Simon Pure Marketing Inc.will limit the collection of Personal Information, both the amount and the type of information, to that which is necessary for the purposes identified by Simon Pure Marketing Inc.  Simon Pure Marketing Inc.will collect your Personal Information by fair and lawful means, and not by misleading or deceiving you about the purpose for which information is being collected.

Principle 5 — Limiting Use, Disclosure, and Retention of Personal Information

  • Simon Pure Marketing Inc.  will not use or disclose Personal Information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. Simon Pure Marketing Inc.will retain your Personal Information only as long as necessary to fulfill the identified purposes.

Principle 6 — Accuracy of Personal Information

  • Simon Pure Marketing Inc.will attempt to make sure that your Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 — Security Safeguards

  • Simon Pure Marketing Inc.will protect your Personal Information by security safeguards appropriate to the sensitivity of the information.

Principle 8 — Openness Concerning Policies and Practices

  • Simon Pure Marketing Inc.will make readily available to you specific information about our policies and practices relating to the management of Personal Information.

Principle 9 — Individual Access to Personal Information

  • Upon written request, subject to certain exceptions, Simon Pure Marketing Inc.will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information.  An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 — Challenging Compliance

  • You have the right to address a challenge concerning compliance with this Privacy Statement to Simon Pure Marketing Inc.’s Privacy Officer.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We may collect personal information from you when you voluntarily provide it to us through a number of features available on this website.  For example, we may ask you to provide personal information if you register for a contest or other promotion.

In addition, if you purchase or otherwise request a product, publication, or promotional offering from us you may be required to provide your contact and/or payment information (such as a credit card number) in order for us to process your request.

Your participation in any of these activities is voluntary and we will only use the personal information you provide for the purposes for which it was collected.  For example, we may use the personal information you provide to: respond to your questions or comments; administer our promotions and sites; fulfill your request, subscription or order; and/or to otherwise provide or improve our products and services. We will not send you any online newsletters or similar e-mail communications unless you expressly consent to receive such a communications from us. We may, however, send you notices of changes to our Privacy PolicyPrivacy Statement.

You may be given the opportunity to consent to receive future promotional communications from us. If you opt-in to receive such communications, we may use the information to: communicate with you regarding our products, services and promotions; provide you with other information that you request; and/or improve our product and service offerings. You will always have the opportunity to “unsubscribe” from receiving e-mail or other communications at any time.

If you contact one of ourConsumer ServicesRepresentatives through this website, we may ask you for personal information such as your name, address, phone number, or e-mail address so that we can respond to your questions or comments.

HOW DO WE GATHER DATA BY AUTOMATIC MEANS?

Sometimes we use cookie technology, web beacons and other similar devices on this website to enhance functionality and navigation for our visitors. Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the website a user visits; and (iv) other websites a user visited before visiting this website. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may be unable to access some customized features on this website. Cookies do not collect or contain your personal information.

Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on this website to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize this website and improve your experience at this website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Like cookies, web beacons do not collect or contain your personal information.

OPT-IN/OPT-OUT OF EMAIL UPDATES

You may have the opportunity to Opt-in(which requires yourexpress consent)and receive email communications from Simon Pure Marketing Inc., in order for you to receive specifically requested information or materials, such as, but not limited to:  a coupon, newsletter, informational materials, marketing communications, or other special promotions or offers, from Simon Pure Marketing Inc.  Simon Pure Marketing Inc.,will only email you if you opt-in to receive specific information or materials. If you opt-in to receive email communications from Simon Pure Marketing Inc., we may send you occasional updates about new additions to Simon Pure Marketing Inc.’s website, as well as, special offers and promotions of which you may take advantage. If at any time you decide you would rather not receive these types of email communications from Simon Pure Marketing Inc., you can opt-out by clicking the unsubscribe link at the bottom of any Simon Pure Marketing Inc. email, update your contact preferences for your account, or contact Simon Pure Marketing Inc.’s Privacy Officer at: [email protected].

HOW DO WE SHARE PERSONAL INFORMATION?

Except as described below, we do not sell, transfer or otherwise disclose to third parties the personal information we collect on this website.  At times we provide your personal information to joint promotion partners and third parties who provide services on our behalf. These entities may use the information solely in conjunction with the specific promotion services they provide for us (e.g. fulfillment of an order; responding to your question or comment; providing a promotional prize; deployment of a consumer survey; investigation of a complaint).

We reserve the right to transfer any personal information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party. Further, we reserve the right to disclose any personal information as needed if such information is requested by law enforcement agencies or if we are requested to do so by law, regulation, court order, or by a government entity. We may also disclose your personal information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) cooperate in any legal investigation; (iii) identify, contact, or bring legal action against someone who may be violating the Terms of Use of this website; or (iv) to protect our rights, privacy, safety or property. Lastly, we may disclose your personal information for any other purpose to which you consent.

LINKS TO OTHER WEBSITES

This website may contain links to the websites of our subsidiaries and affiliates, and to websites that are independently owned and operated by third parties. These other websites may have their own privacy policies and are not governed by this Privacy PolicyPrivacy Statement. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any such subsidiaries, affiliates or third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policyPrivacy Statementfor each website you visit.

CHILDREN’S PRIVACY

We are committed to protecting the privacy of children and we do not knowingly solicit personal information from children under the age of 13.  If a child has already provided us with personal information, his or her parent or guardian may contact us for the purpose of deleting this information.

CANADA ONLY

This website is intended for use by residents of Canada only. All matters relating to this website are governed by the laws of the Province of Ontario and the laws of Canada applicable therein. If you are located outside of Canada, and you contact us, please be advised that any personal information you provide to us will be transferred to Canada and that by submitting information, you explicitly authorize its transfer.

HOW WE PROTECT PERSONAL INFORMATION

The security of your personal information is important to us. We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website.  Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure.  As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.  All third parties that obtain personal information from us (e.g. service providers that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

Some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.  Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

CHANGES TO THIS PRIVACY POLICYPRIVACY STATEMENT

We reserve the right to change or replace this Privacy PolicyPrivacy Statementat our sole discretion at any time. Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy PolicyPrivacy Statement.  We will indicate at the top of this page the date this Privacy PolicyPrivacy Statementwas last revised. Your continued access or use of this website after any such changes constitutes your acceptance of the Privacy PolicyPrivacy Statementas revised.

YOUR CONSENT TO THE TERMS OF THIS PRIVACY POLICYPRIVACY STATEMENT

By using this website you consent to the terms of this Privacy PolicyPrivacy Statement, you signify your assent to all of the terms of this Privacy PolicyPrivacy Statementand our Terms and Conditions. If you do not agree with any terms of this Privacy PolicyPrivacy Statementor our Terms and Conditions, please do not use this site or submit any personal information.

HOW TO CONTACT US

We welcome your feedback. If you have questions, comments or concerns about our Privacy PolicyPrivacy Statement, or would like to do any of the following:

  • see personal information that you have already sent us so that you can correct or update it
  • delete your personal information from our files;
  • if your child under 13 has sent us personal information, delete that personal information from our files;
  • ask that we not send you mailings or otherwise contact you; or
  • report any violation of this Privacy PolicyPrivacy Statement

Please contact us at:

Simon Pure Marketing Inc.
C/o Josh Dyan
100 Broadview Ave, Suite 319
Toronto, ON M4M3H3
Canada
Tel: 647 286 9392
Email:[email protected]