PRIVACY POLICY

Introduction

British Group (consisting of British Confectionery Company Ltd., British Group of Companies, and all their affiliated companies) ("BGI" or "we") is committed to protecting your privacy and is bound by Canadian privacy laws (including but not limited to the federal Personal Information Protection and Electronic Documents Act) to protect your privacy.

This Privacy Policy explains the steps we take to protect your personal information. It describes what categories of personal information we collect, how we hold and collect that data, the purposes for which we use and disclose that data, your choices regarding use of personal information about you, our security measures, and how you can review and correct data about you. By dealing with us, you consent to the data collection, and use and disclosure, practices described in this Privacy Policy.

Data Collection and Purpose

We collect and store the personal information we need to provide our products, services and information to our customers, our partners, our contractors and other affiliated entities, for our functions and activities, and to comply with the law. If you choose not to provide certain personal information to us, we may not be able to assist you, or provide you with the requested service or product. If you provide us with your personal information, and we have not solicited that data, we may destroy or de-identify it.

If appropriate, we will generally tell you, or it will be obvious from the circumstances, why we are collecting personal information when we collect the information and how we plan to use or disclose the information.

We will generally collect information relating to you directly from you. However, we may collect information about you from a third party, such as a contracting company or via third party service providers, or from publicly available reference sources. The following are the main types of personal information collected and held by us and the main purposes for which they are collected and held. Data collected from visitors to our websites. In most instances, you can visit our websites without providing any personal information. However, on some pages, we may ask you for personal information to provide a service or carry out a transaction you request including but not limited to entering sweepstakes, contests and competitions. The personal information that we collect may include:

  • contact details, such as your name, title, company/organization name, e-mail address, telephone and fax numbers, and physical address;
  • your preferences with respect to e-mail marketing;
  • your inquiries about our products and services, including contests, competitions and sweepstakes as well as information that assists us in identifying the best products and services for you;
  • contest entry and event registration information; and
  • feedback from you about our products and services, including our websites.

We also automatically collect certain data about all visitors to our websites, including what pages they view, the number of bytes transferred, the links they click, and other actions taken within our websites. On websites to which you logon, we may connect this information with your identity to determine your potential interests in our products and services. We may also use this information to improve our security measures. We also collect certain standard information that your browser sends to every website you visit, such as your Internet Protocol (IP) address, your browser type and capabilities and language, your operating system, the date and time you access the site, and the website from which you linked to our site. We do not link this data to your identity.

Purpose of Collection of personal information

We use personal information collected from our websites to deliver services or execute transactions you request, such as providing information about our products and services, answering customer service requests or facilitating use of our websites. In order to offer you a more consistent experience in interacting with us, information collected by our websites may be combined with information we collect by other means.

We may also use data about you to improve our websites (including our security measures) and related products or services, or to make our websites easier to use by eliminating the need for you to repeatedly enter the same information or by customizing our websites to your particular preference or interests.

Employees and Contractors. We collect personal information about individuals who are employed by or contracted to us or our related companies. These data may include contact details, job title and history, salary and benefits information, employment history, job performance information, information regarding use of our resources, bank account number, expense reimbursement information and other information that is reasonably necessary for our functions or activities. In certain circumstances this may include sensitive personal information, such as health information, nationality, and trade union membership information when required by law or in order to provide you with benefits.

We may use information collected from you for our functions and activities, including human resources management, recruitment, training, performance management, succession planning, meeting legal requirements, facilitating business transactions and protecting us, our workforce personnel or the public against injury, theft, legal liability, fraud, abuse or other misconduct.

Marketing Communications. With your permission, we may use personal information to inform you of products or services available from us or our affiliated entities. When collecting information that might be used to contact you about our products and services, we give you the opportunity to opt-out from receiving such communications. Moreover, each e-mail communication we send includes the ability to unsubscribe allowing you to stop delivery of that type of communication. If you elect to unsubscribe, we will remove you from the relevant list within 10 business days.

Our use of your personal information

We generally use, transfer and disclose personal information for the purposes for which it was collected, as described above. Some of this information may include sensitive personal information, including health, and will only be used for compliance with applicable laws and regulations including workplace laws.

In fulfilling these purposes, we may transfer or disclose certain personal information to particular third party service providers including affiliated entities. These external and internal organizations include payroll companies, insurance companies, information technology consultants, and document management companies.

Where appropriate, we may handle personal information relying on exemptions that are available under applicable privacy laws, including, for example, the audit and employee records exemption in the privacy legislation.

Our use of cookies and web beacons

Cookies are small files that websites save to your hard disk or to your browser's memory. Our websites may use them to track the number of times you have visited the website, to track the number of visitors to the website, to determine and analyse visitors' use of our websites, to store data that you provide (such as your preferences), and to store technical information related to your interactions with our websites and other administrative purposes. We may also use session cookies, which are deleted when you close your browser to store your user ID, to facilitate your movement around our websites (particularly in connection with information searches and contest entries) and other information useful in administering the session.

Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose not to accept cookies, you may not be able to experience all of the features of our websites. Internet browsers also enable you to delete existing cookies, although this means that your existing settings (including stored user IDs and other preferences) will be lost.

Our sites also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us to count the number of users who have visited those pages. We may include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon, including whether the recipient clicked on a link in the email or forwarded the email to another person.

Disclosure of your personal information

Subject to any restrictions imposed by any relevant legislation, we may disclose your information to our affiliated entities. As well, we contract with suppliers, service providers, professional advisers and agents. The type of service providers we may disclose personal information to include:

  • professional advisors such as lawyers, accountants and auditors;
  • data storage providers;
  • agents and contractors, such as payroll companies, insurance companies, information technology consultants, that provide services to us as appropriate and necessary; and
  • other companies who provide services on our behalf, such as hosting websites, sending out information, processing transactions, and analyzing our websites.

We provide these companies with only those elements of your personal information they need to deliver those services. These companies and their employees are prohibited from using those personal information for any other purposes.

In connection with certain transactions including, for example, contests, competitions and sweepstakes, we may disclose some or all of the personal information you provide to financial institutions, government entities, and shipping companies or postal services involved in fulfilling the transaction including prize fulfillment.

Some of our websites may promote collaboration among registered users with respect to a particular area or topic. On those websites, we may share your username with other participants to label comments or suggestions that you make as yours. We do not, however, share your name, contact details, or other personal information with other users of those collaborative websites.

We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements in Canada or other jurisdictions outside Canada or with legal process served on us, to protect and defend our rights or property, or in urgent circumstances to protect the personal rights or safety of any individual. We may also disclose your personal information if you have consented to its disclosure.

Security

We are committed to protecting your personal information. While no security measure can guarantee against compromise, we use a variety of security technologies and procedures to help protect your personal information from misuse, interference and loss, and from unauthorized access, modification, or disclosure. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.

We retain all personal information subject to our procedures and policies relating to data retention, which require that personal information be destroyed in a manner that protects the confidentiality of the data when its retention period expires.

Security on the Internet. When you move around a website to which you have logged in, or from one site to another that uses the same login mechanism, we verify your identity by means of an encrypted cookie placed on your machine. If you place an order with us, enter a contest, competition or sweepstake, view account information, or provide financial information, we protect the transmission of such data using Secure Socket Layer (SSL) encryption.

For websites to which you login, it is your responsibility to ensure the security of your password and not to reveal this information to others. If you are sharing a computer with anyone you should always logout before leaving a website so that subsequent users will not be able to access your data.

Reviewing and correcting your personal information

You have a right to access and request correction of most personal information that we have about you. In some circumstances it may not be possible for us to provide you with all of your personal information, or an exemption under applicable privacy legislation may apply. Where we will not provide access to personal information held about you, we will tell you why.

If you think that any personal information we hold about you is inaccurate, you may contact us using the contact details below and we will take reasonable steps to ensure that the information is corrected. We may take steps to verify your identity before providing you access to personal information. You can help us to keep data about you accurate by notifying us of any change to your mailing address, phone number, or e-mail address.

Any requests for access to or correction of personal information will be responded to within a reasonable period after the request is made.

If you wish to make a complaint about the way we have handled your personal information (including if you think we have breached the privacy legislation) you may do so by contacting us in writing, by mail or email to the address or email address set out at the end of this Privacy Policy. If a complaint is made, please include your name and contact details such as an email, address and telephone number and clearly describe the complaint. We will investigate the complaint and respond promptly.

If you consider that we have failed to resolve the complaint satisfactorily, you can also complain to the federal or applicable provincial Privacy Commissioner.

Links to other websites

Our websites may contain links to other websites, including those of other companies, professional and government organizations, and publications. While we try to link only to websites that share our high standards and respect for privacy, we do not control and are not responsible for the content, security, or privacy practices employed by other websites. You should review the privacy policies of those websites to determine how they protect and use your personal information.

Children

This website is a general audience website, although it contains information that may be of interest to children. Except in the case where we conduct a competition designed for children, we do not seek through this site to gather personal information from or about persons 14 years or younger. If we do conduct a competition directed at children, we will include an additional privacy notice for children as part of entry into such competition.

Questions or complaints about our privacy practices

If you have questions or complaints regarding this Privacy Policy or our handling of your personal information, please contact us by email, or by mail at:

British Confectionary Company Ltd.
187 Kenmount Road, Suite 201
St. John's, NL
A1B 3P9
Canada

Attention: Privacy Officer
Email: info@britishgroup.ca

Changes to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will revise the "last updated" date at the bottom of the privacy policy. You should revisit this page periodically to become aware of the most recent privacy terms; your use of the site after such changes have been posted constitutes your agreement to such changes.

2017 British Confectionery Group Inc.

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