Updated: April, 18 2018
PART A – COLLECTION OF INFORMATION
Information contained on the Services is collected by Passen from consumers and from stores partnered with Passen (“Partners”). We obtain your express consent to use your information when you complete a Customer Profile with us, and we always obtain your express consent to collect your Personal Data when you require that your Customer Profile be updated.
We may collect additional Personal Data that you disclose to us through your use of the Services as well as other information as set out below.
1. Personal Data You Provide
Your voluntary disclosure of Personal Data may include, but not be limited to:
· basic Personal Data, including your name, height, weight, gender, and age;
· contact information, including phone number, email, and mailing address; and
· any feedback you provide regarding our products and services which may have content which is Personal Data,
as you engage with the Services to assist with your shopping experience.
Collection of this Personal Data is necessary for us in order to carry out the applicable actions (as set out under Part B below). If you do not consent to certain uses of information, we may not be able to provide you with a particular benefit or service.
2. Information Collected Automatically
During your interaction with the Services, we may collect and store anonymous information (“Automatic Information”) about you using various technologies including, without limitation, Cookies, which are alphanumeric identifiers that are stored on your device with which you access the Services, and Internet tags. Some of this information is automatically transmitted to us through your browser.
PART B – USE OF YOUR INFORMATION
To accomplish any of the purposes listed below, we may combine Personal Data and Automatic Information, and non-Personal Data collected through your use of our Services. This information may be used in a variety of ways which are in keeping with the intent behind the collection of information. For instance, the Personal Data provided by you may be used:
· to provide Partners with detailed information about your body measurements to assist in identifying outfits for you;
· to identify shopping habits and better pinpoint suitable attire;
· to provide recommendations for better fitting attire;
· to perform internal reviews of the effectiveness of Passen software;
· to prepare reports for Partners including aggregate data of their customer base; or
· to improve our services or provide you with information you requested.
In addition, the Automatic Information collected may be used to, among other things:
· monitor characteristics of and statistics on Services usage; and
· refine our Services’ features and functionality.
We also reserve the right to use Personal Data and Automatic Information as set forth in our Terms, if applicable.
PART C – DISCLOSURE OF YOUR INFORMATION
1. To Help with Business Operations
In addition to the above-listed uses, we may disclose your information to the extent required to administer your benefits. For example, we may disclose your Personal Data to Partners other than the ones you currently shop with, but who may be of interest to you in the future. From time to time, we may engage companies or individuals for certain services on our behalf including, without limitation, conducting audits, performing legal services, collecting feedback, and providing customer service. Our Business Partners and any other third-party service providers will only have incidental access to Personal Data to the extent required to perform their services. They are prohibited from the use of your Personal Data for any purpose other than assisting with our business operations.
2. Safety and Security
We may also disclose your information as necessary to protect the safety or security of users of our Services, to detect and prevent fraud or abusive behaviour, or when otherwise required or permitted by law.
3. Transfer or Sale
4. Legal Requirement
We may disclose your information, if required, to:
· supervisory authorities, tax authorities, police and other regulatory authorities as required by law or in response to a subpoena, court order, or other legally valid inquiry or order; and
· to either prevent/minimize a criminal offense or to protect a person’s rights and personal and or financial health.
PART D–PROTECTING, RETAINING AND STORING YOUR PERSONAL DATA
1. Protection. In order to help prevent unauthorized access to, maintain data accuracy and ensure the correct use of your information, we have put in place commercially reasonable physical, electronic (e.g. SSL (secure socket layer) server authentication) and managerial procedures to safeguard and secure the information we collect through our Service. That said, we cannot guarantee that information provided to us will remain private, or that the information you transmit to us over the Internet will not be intercepted.
2. Storage. We have strict safeguards in place to ensure that your personal information, in both paper and electronic form, is only accessed internally by those who need it to service users. All of our employees, agents and representatives are aware of the sensitive nature of the information we hold and have agreed in writing to keep personal information in their possession strictly confidential.
3. Identification. To help prevent unauthorized access to your Personal Data you are responsible for keeping the username and password (collectively, “ID”) that you receive upon opening any accounts with us private and confidential. You are solely responsible for preventing the unauthorized use of your ID. If you suspect that your information has been compromised or that your account has been accessed without your consent, please contact us immediately at firstname.lastname@example.org
4. Retention: We may store your Personal Data from the date of collecting such information for a period of 5 years after your membership expires or service access is terminated, whichever period may be longer. It is securely destroyed or anonymized thereafter.
PART E – ELECTRONIC COMMUNICATIONS
Should you submit an inquiry through our Services, or otherwise communicate with us electronically, you consent to us responding to such inquiries electronically. We cannot guarantee that information that we send to or receive from you over the Internet will not be intercepted.
PART F – ACCESSING AND MODIFYING YOUR PERSONAL AND ACCOUNT INFORMATION
We want to ensure your Personal Data is accurate and up to date. If you notice any inaccuracies, please let us know. You can also access and modify your personal and account information using the tools provided in our Services. We will not modify your personal or account information.
At any time, you may request access to your Personal Data by contacting email@example.com. We will respond to your request within a reasonable time period, and process it “as appropriate under applicable law”. Your request may be subject to a processing fee as allowed under law.
PART H – HOW TO CONTACT US
Attention: Customer Service
1313 – 1 Market St.
Toronto, ON M5E 0A2