Last Updated: October 2020
Welcome to CPM Group!
• Visitors to our websites;
• Visitors to our premises;
• Customers; Potential Employees; and
2. IMPORTANT INFORMATION AND WHO WE ARE
2.2 Contact Us
3. WHAT DATA DO WE COLLECT ABOUT YOU
3.1 Personal data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
• Profile Data includes your username and password, purchases, or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.2 Aggregated Data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic, and biometric data). Nor do we collect any information about criminal convictions and offences.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
(a) Visitors to our websites
When you visit our websites, we use third party service providers (including Google Analytics and Adjusts) to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the websites. This information is only processed in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our websites.
You may decide to submit personal information to us through the website, for example, when purchasing goods or services, signing up to a newsletter, filling in a survey, or entering a competition. When we collect personal data in this way this policy sets out what we intend to do with it.
Visitors and Users from outside of the Canada should note that we collect, process and store information in the Canada we collect from our Sites and Forums. By using our Sites and Forums from locations outside of the Canada, you consent to the transfer of your personal information to, and the collection and processing of such personal information in the Canada. The laws pertaining to the collection, use, disclosure, and processing of personal information in the Canada may vary from those in other countries and may be less or more stringent than the applicable laws in your state or country. Accordingly, those who choose to access and provide personal information to our Sites and Forums from outside of the Canada do so based on their own initiative and are solely responsible for compliance with applicable local laws.
(c) Search Engine
Search queries and results of searches on our website are logged anonymously to help us improve our website and search functionality. We do not collect any user-specific data.
(d) Security and performance
To maintain the security and performance of our websites we use a third party service which processes the IP address of visitors and other Technical Data.
This information is retained for a maximum period of 24 months.
(e) Social Media
We use various social media channels, including Wechat, Weibo, Facebook and Twitter and will process your personal information when you interact with us (for example by liking or sharing a post). We use this information to improve our services.
(f) Online accounts
When you set up an online account with us, we will request personal data from you in order to verify your identity and set up your account. This information will also be used when you interact with us through the websites.
We will keep this information for a period of at least 5 years from the date of your last log in to the service, unless you have purchased goods and/or services through our websites or opted in to marketing communications in which case such accounts will be kept active for so long as we keep such information in line with the rest of this policy.
(g) Internet Based Advertising
These and other third parties may also collect data about your online activities over time and across different websites when you use Cpromo's websites.
Cpromo may also work with third parties to serve advertisements to you as part of a customized campaign on other websites or platforms.
Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many other websites and online services, Cpromo currently does not alter its practices when it receives a "Do Not Track" signal from a visitor's browser. To find out more information about "Do Not Track," you may visit http://www.allaboutdnt.ca.
Please note that electing to opt-out will not stop advertisements from appearing in your web browser or applications. If you use a different browser, erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choices. Also, any cookie blocking setting that you implement may not block the use of non-cookie technologies by third parties.
In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative ("NAI"). The NAI has developed a tool that allows consumers to opt out of targeting advertising delivered by NAI members' ad networks. To learn more about opting-out or using the tool, visit http://www.networkadvertising.org/choices/. Cpromo is not responsible for the effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs. Your choices are both browser- and device-specific.
(h) Children's Privacy
Our websites are not intended for children under the age of thirteen (13) and we do not knowingly collect data relating to children. If you are a child under the age of thirteen (13), you are not permitted to use our Sites and Forums and should not submit any information about yourself to us. If we learn that we have received information from a user under the age of thirteen (13), we will promptly delete any information associated with that user.
4.2 Third-party links
Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
4.3 Direct interactions
We may collect personal information from our direct interactions with you. This may include through correspondence, email, text messages, applications, phone calls, attendance at meetings with you, or other direct interactions.
4.4 From third parties
We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data analytics providers such as Google, Yandex, and others based both inside and outside the Canada;
• Contact Data from providers of technical services;
• Identity and Contact Data from data brokers or aggregators;
• Identity and Contact Data from publicly available sources;
5. HOW IS YOUR INFORMATION USED?
We may use your personal data for various purposes, including the following:
• To register you as a new customer, including verifying your email address(es) are active and enrolling you in various Cpromo programs;
• To facilitate, improve, and personalize your online experience;
• To manage your account(s), including purposes, orders, payments, and comments;
• To communicate with you about products, services, offers, promotions, rewards, and events, including those offered by third parties;
• To administer and enable you to partake in a prize drawing, promotions, competitions, or sweepstakes;
• To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising or understand the effectiveness of the advertising that we serve to you;
• To use data analytics to improve our platforms, products/services, marketing, customer relationships and experiences, we analyze audience acquisition, behavior and conversions;
• To make suggestions and recommendations to you about goods or services that may be of interest to you;
• To monitor our websites for compliance with our Terms of Service Agreement;
• Respond to subpoenas or other legal processes and government investigations;
• To monitor and prevent fraudulent activity and threats;
• To perform other business activities as needed or described elsewhere in this policy;
• Any other purpose, with your consent or as permitted or required by applicable law.
We strive to provide you with choices regarding certain personal data uses, particularly around whether you want to receive marketing and advertising offers.
6.1 Promotional offers from us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us, purchased goods or services from us and if you provided us with your details when you participate in a competition, online campaign, or registered for a promotion, in each case, you have not opted out of receiving that marketing.
6.2 Sharing of Information
We may from time to time share your personal data with third parties for marketing and other purposes. This may include sharing of such information with other members of the Cpromo Group. For example, your personal information may be disclosed:
• To any subsidiary and affiliated entities that we control, that control us, or that are under common control with us.
• Whenever you consent to such disclosure.
• To third party businesses offering goods and services via our Sites and Forums.
• When you participate or post in any of our community forums or other public areas of our Sites and Forums. Please note that information you post or disclose through these forums or other public areas may be other users of the Sites and Forums and to the general public, so be careful when deciding to disclose any personal information.
• To our third-party service providers who provide services such as website hosting, data analysis, payment processing, information technology and related infrastructure, email delivery, text messaging, auditing, customer relationship and other services.
• In connection with, or during negotiations of, any proposed or actual merger, purchase, sale, assignment, joint venture or transfer of any other type of all or any portion of Cpromo's business, assets, financing, or stock including in connection with any bankruptcy or similar proceedings.
• To the maximum extent permitted by applicable law, to copyright owners, Internet Service providers, wireless service providers, or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you.
• To third parties for marketing purposes. This may include third parties whose products or services we believe you may be interested. These third parties may also share your information with others. These third parties may use your information for their own marketing purposes and pursuant to their own policies.
6.3 Ability to Opt out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us.
Even if you opt out of receiving these marketing messages, this will not prevent our collection of personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
7. PRODUCT AND SERVICE DEVELOPMENT
We use Aggregated Data to develop our services and products, but we may from time to time use your personal data, including feedback, responses to polls and surveys and other information provided by you to also improve our business. For example, this may include using recordings of calls for training purposes, and we will tell you if this is likely to be the case. You can ask for the call to not be used in this manner. We may also use personal information that you have provided (including your communications with us) to offer better customer support and fix problems.
8. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out above. These parties may be:
• Other members and affiliates of the Cpromo Group who provide us with services to enable us to operate our business. We may also share personal data so that we can improve the Cpromo Group's products and services as a whole.
• Third party service providers (acting as processors) who provide IT and system administration services and support.
• Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• We may also share your information at your direction or request, or when you otherwise consent.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. WHERE IS YOUR INFORMATION STORED OR TRANSFERRED
The information we collect from you may be transferred to, stored at, and processed in destinations inside or outside of the country in which you are located and may be accessible to the governments of such destinations under local law. This includes use by us. Other members of the Cpromo Group and many of our external third party suppliers are based outside the Canada so their processing of your personal data will involve a transfer of data outside the Canada.
Whenever we transfer your personal data out of the Canada, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Canada and the US.Please contact us (our contact details are set out above) if you want further information on the specific mechanism used by us when transferring your personal data out of the Canada.
10. DATA SECURITY
We have put in place appropriate security measures to help prevent your personal data from being lost, used or accessed in an unauthorized way, altered, destroyed, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Although Cpromo uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Cpromo cannot guarantee the security of your information collected through our service. Further, you are responsible for protecting your password.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. CHOICES REGARDING YOUR INFORMATION
You have certain choices about how we use your personal information. They are summarized below:
11.1 Request access to your personal data (commonly known as a "data subject access request").
You may receive a copy of the personal data we hold about you.
11.2 Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
11.3 Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
11.4 Object to processing of your personal data
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms you may object to our processing of your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
11.5 Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
11.6 Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
11.7 Withdraw consent at any time
Where we are relying on consent to process your personal data you may withdraw this consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
11.8 How to exercise your rights
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11.9 Your right to complain to the relevant supervisory authority.
You have the right to make a complaint at any time to your relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us (our contact details are set out above) in the first instance.
12. UPDATING YOUR PERSONAL INFORMATION
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
You may contact us to review, update, or modify personal information that you have provided to us or request that we deactivate your account. We may retain certain personal information in our archives for record-keeping purposes. We do not have the ability to remove information from the databases of third parties with which we have already shared your information.