ESTEAM MANUFACTURING LTD ONLINE POLICY
Updated November 2018
WHAT IS PERSONAL INFORMATION?
INFORMATION WE COLLECT
Information we may collect from you includes your:
• 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.
Esteam Manufacturing Ltd. provides cleaning products for the carpet cleaning, janitorial, auto detailing and restoration industries. As such, we may also collect personal information from individuals participating in and / or impacted by these activities.
As a general rule, Esteam Manufacturing Ltd. 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
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 Esteam Manufacturing Ltd. 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.
Esteam Manufacturing Ltd. may, subject to applicable laws, use personal information to contact you about our Websites and services, including to provide information on additional products from Esteam Manufacturing Ltd. that may be of interest to you, though you may withdraw your consent. You can always limit the communications that Esteam Manufacturing Ltd. 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 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. 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.
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 or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made de-identified.
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 industry-standard security measures to protect the confidentiality of personal information under our control and appropriately limit access to it. However, 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.
LINKS TO THIRD-PARTY WEBSITES
CROSS-BORDER TRANSFER OF PERSONAL INFORMATION
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 Esteam Manufacturing Ltd., if applicable, please send an e-mail message to firstname.lastname@example.org 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.
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 email@example.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).
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.
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.
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, OBJECTION, 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 your personal information. If you want to 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 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.
QUESTIONS AND COMMENTS
Esteam Manufacturing Ltd.
c/o Safety Express Ltd.
D1-3680 Odyssey Drive
Mississauga, ON L5M 0Y9
Attention: Privacy Officer