PRIVACY POLICY
Updated June 1, 2023
Safety Express Ltd. (“Safety Express”) knows that you care about the collection and use of your information and thus has created this Privacy Policy to describe how we collect, use, share and protect your personal information.
We may need to update our Privacy Policy, and if we choose to do so, we will post the changes on our website at safetyexpress.com (the “Websites”). Such changes shall apply to information collected after the date of the change. We recommend that you review this Privacy Policy periodically.
It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes such legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable. As a result: (i) this Privacy Policy has a limited scope and application; and (ii) the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.
WHAT IS PERSONAL INFORMATION?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than an individual's business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities. (Notwithstanding, access and rectification rights apply to such business contact information under Quebec privacy law, as applicable.)
INFORMATION WE COLLECT
You can visit our Website without telling us who you are or revealing any information about yourself, including your e-mail address. Our web server may collect information related to your visit to our Website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our Website, the page you entered and exited at, any Website page that is viewed by that IP address and what country you are from. We use this information to monitor our Website's performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our Website.
We collect and maintain different types of personal information in respect of the individuals with whom we interact. For example, we may collect and store the personal information that you provide us when you place an order on our Website, create an account, call us with a question, respond to communications such as e-mail, or participate in another Website feature. We collect your information for the purposes described in this Privacy Policy.
Information we may collect from you includes your:
- Name;
- E-mail address;
- Mailing address;
- Phone number;
- Credit card, debit card or other checking account information;
- Transaction information; and
- Credit application information, such as your Social Security information.
Safety Express provides safety equipment for the abatement, restoration, environmental and industrial industry. As such, we may also collect personal information from individuals participating in and / or impacted by these activities.
As a general rule, Safety Express collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
Where permitted or required by applicable law or regulatory requirements, we may collect, use or disclose information about you without your knowledge or consent.
HOW WE COLLECT YOUR INFORMATION
We collect information related to your interactions with us. If you access our Websites, we may collect information including your IP addresses and browser behavior, to analyze trends, administer the Website, track user activities, infer user interests, and otherwise induce, deduce, and gather information about individual users and market segments. Your information may be collected through common technology such as "cookies," as is further described below. We will only use personal information to the extent it is necessary to fulfill the purposes for which it was collected or as otherwise disclosed in this Privacy Policy.
DO NOT TRACK SIGNALS
Because there is as of yet no common understanding of how to interpret Web browser-based Do Not Track (“DNT”) signals, we do not currently respond to undefined DNT signals.
HOW WE USE YOUR INFORMATION
We may use the information we collect from you for things like:
- Establishing, maintaining and managing our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
- Allowing us to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
- Customizing your experience on our Websites and identifying your preferences;
- Responding to your customer service requests;
- Conducting market research and analysis;
- Improving our products;
- Processing transactions and fulfilling orders; and
- Protecting Safety Express against error, fraud, theft and damage to our goods and property.
We may also use your information:
- to enable us to comply with applicable law or regulatory process;
- as permitted by applicable law or regulatory requirements; and
- any other reasonable purpose to which you consent.
Safety Express may, subject to applicable laws, use personal information to contact you about our Websites and services, including to provide information on additional products from Safety Express that may be of interest to you, though you may withdraw your consent. You can always limit the communications that Safety Express sends to you. To opt out of commercial e-mails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt out of promotional communications, we may still need to contact you with important information about your account.
HOW WE SHARE YOUR INFORMATION
Except as described herein, we will generally not sell, trade, or otherwise transfer to outside parties your personal information unless we provide you with advance notice.
For example, we may also share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, we may share your personal information from time to time with our third-party information technology, data processing and call center service providers so that we may operate the Websites, conduct market research and analysis, conduct our business, or provide services to you. In all such cases, we will comply with the applicable legal requirements for the communication of personal information with third parties.
In the event that we sell our company or otherwise transfer any assets of our company, we may provide your information to the purchaser so that you may continue the relationship or business with us and our products, in which case we will comply with applicable legal requirements for the communication of personal information in such context. We may also release your information when we believe that the release is appropriate to comply with the law, when permitted by applicable law or regulatory requirements, enforce the Websites’ policies, or protect our or others' rights, property, or safety. We may also disclose personal information when such disclosure appears necessary to comply with a subpoena in the course of managing a dispute, governmental inquiry or other litigation process.
We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights in accordance with or as authorized by law. We will obtain assurances from our agents that they will safeguard personal information consistently with this Privacy Policy. Examples of appropriate assurances that may be provided by agents include a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles, being subject to Regulation (EU) No 5419/16 (“General Data Protection Regulation” or “GDPR”), or being subject to another European Commission adequacy finding. Where Safety Express has knowledge that an agent is using or disclosing personal information in a manner contrary to this Privacy Policy, Safety Express will take reasonable steps to prevent or stop the use or disclosure. However, non-personally identifiable Website visitor information may be provided to other parties for marketing, advertising, or other uses.
RETENTION OF YOUR INFORMATION
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients in accordance with applicable law, or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased, de-identified or anonymized as required, subject to preservation periods provided for by applicable law.
HOW WE USE COOKIES
We collect information through cookies. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. Cookies are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We may employ third-party service companies to process your information to assist us in better understanding the Websites’ visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
Through your browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. We do not control and cannot guarantee the effectiveness of third-party cookie-management tools.
SAFEGUARDING PERSONAL INFORMATION
We use physical, technical and procedural safeguards that are reasonable according to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. We will notify you of any loss of data or breach of our security measures that has resulted in the loss or unauthorized access, disclosure, use or acquisition of personal information or otherwise presents a potential threat to such information, without undue delay, as required by law, and we will comply with applicable legal requirements for reporting, documenting and responding to such incidents. Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
LINKS TO THIRD-PARTY WEBSITES
Our Websites may contain third-party links to sites operated and maintained by third parties over which we have no control. We have no responsibility or liability for the content and activities of any third parties or third-party websites, including any linked sites. Many of these sites have their own privacy policies and this Privacy Policy applies solely to information collected by the Websites. We encourage you to review the privacy policies of such websites before disclosing your personal information to them.
CROSS-BORDER TRANSFER OF PERSONAL INFORMATION
It is important to note that the Websites are operated in the United States. In some cases, personal information that we manage may be transferred to and stored in the United States for the purposes described in this privacy policy (e.g. to enable third parties to provide services to us or on our behalf). You understand that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to law enforcement, national security, and government authorities in such foreign jurisdictions—which may not have the same privacy and data security laws.
In any case, we will comply with applicable legal requirements for cross-border data transfers and take such steps as are reasonably necessary to protect your information in accordance with the law and industry standards.
CALIFORNIA PRIVACY RIGHTS
California residents who provide personal 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 customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). To obtain this information from Safety Express, if applicable, please send an e-mail message to info@safetyexpress.com with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.
CHILDREN'S PRIVACY
Our Website and services are not directed at children and we do not knowingly solicit or collect personal information from children. If you become aware that a child has provided us with personal information, please contact us promptly by sending an e-mail message to info@safetyexpress.com with "Request for Child Information Removal" in the subject line and the name and age of the child in the body of the message. We will then make reasonable efforts to delete the child's information from our database and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law).
CONSENT
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy and as permitted by applicable law.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. Please note that in some circumstances, withdrawing or changing your consent to certain uses of your personal information may affect: (i) our ability to provide you with the products or services you request; and (ii) your ability to access the Websites.
ACCESS, CORRECTION, AND DELETION
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
You can also ask to see (or obtain a copy of) your personal information and request that it be corrected, or deleted, if it is inaccurate, incomplete, or equivocal, or if collecting, disclosing or keeping it is not authorized by law. If you want to access, review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access, correction or deletion of the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
RIGHT TO LODGE COMPLAINTS
We endeavor to be transparent about the ways in which we collect, use and disclose personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you may lodge a complaint with any applicable privacy commissioner in Canada.
INTERPRETATION OF THIS PRIVACY POLICY
Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word "including" is used, it shall mean "including without limitation."
This Privacy Policy does not impose upon Safety Express any obligations, or create or confer upon any individual any rights, outside of, or in addition to, those imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
CHANGES TO OUR PRIVACY POLICY
We will review and update this Privacy Policy, for example, as required to keep current with rules and regulations, new technologies, and security standards. As noted above, we will post those changes on the Websites and update the Privacy Policy modification date above. In certain cases, and if the changes are material, we will provide written notice to clients directly by e-mail or otherwise, if required by law.
QUESTIONS AND COMMENTS
If you have any questions or comments about our Privacy Policy, please contact our Privacy Officer by e-mail at info@safetyexpress.com with "PRIVACY POLICY" in the subject line or by mailing us at the following address:
Safety Express Ltd.
D1-3680 Odyssey Drive
Mississauga, ON L5M 0Y9
Attention: Privacy Officer
