Effective Date: JUNE 25, 2020

CTC TRIANGLE (USA) LLC PRIVACY POLICY

Policy on Privacy of Customer Personal Information

CTC USA is committed to protecting the privacy and security of your personal information obtained by reason of your customer relationship with CTC USA. The CTC USA Privacy Policy (“Privacy Policy”) explains the types of customer personal information we collect, how it is used, and the steps we take to ensure your personal information is handled appropriately. This Privacy Policy applies to our customer personal information practices in our stores, on our websites, mobile applications and through other interactions with you.

Our policies and practices have been designed to comply with federal, provincial and state private sector privacy acts and other applicable laws regarding the protection of your Personal Information in the jurisdictions in which we operate, including federal and state laws of the United States. Our Privacy Policy may be amended from time to time. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change. Changes to our policy will be communicated to you by way of a message posted on our website. If you continue to use our products and services after the effective date of change, you will be deemed to have accepted the changes to our policy. A copy of the most current version of our Privacy Policy may be obtained on our website or by contacting us (See Contact Information, below). We encourage you to review the current Privacy Policy from time to time.

Navigating This Privacy Policy:

If you are viewing this Privacy Policy online, you can click on the links below to take you to the relevant section.

Who is CTC USA?

For purposes of this Privacy Policy, “CTC USA” means CTC Triangle (USA) LLC , a wholly-owned subsidiary of Canadian Tire, and its affiliates and subsidiaries. "Canadian Tire" means Canadian Tire Corporation, Limited and its family of companies including Mark's, FGL Sports Ltd., Helly Hansen, and PartSource. CTC USA also includes a number of banners and brands which you may interact with, including but not limited to, Woods, Sher Wood, Paderno, Forward With Design, Noma, Outbound, Type A, Motomaster and Maximum. CTC USA also includes any successors or subsidiaries of the above-listed companies. Canadian Tire stores and certain Mark's and FGL stores are owned and operated by independent dealers or franchisees. Canadian Tire gas bars are operated under license by independent retailers. As independent businesses within the Canadian Tire family of companies, these dealers, 

franchisees, and retailers are responsible under applicable laws for adopting their own privacy policies to protect your personal information in a manner consistent with this Privacy Policy.

How We Collect Personal Information:

  • Directly from you, such as information you provide to us when you inquire or purchase our products and services.
  • From our vendors, partners, and third parties who we work with to provide and improve our products and services.
  • From companies and organizations that partner with us to deliver products and services.
  • Automatically, from your use of our website or apps, such as your IP address, usage data, and geolocation data.

Automated Collection

We automatically collect some information and data about your computer and mobile devices when you visit our website. To collect this information, we may use cookies, web beacons, and similar technologies.

At this time, we do not respond to Do-Not-Track signals. If you would like additional information about online tracking and various opt-out mechanisms, please see http://donottrack.us/ Please note that not all tracking will stop even if you delete cookies.

Behavioral Advertising:

As described above, we use personalized online advertising on the website to ensure that the advertising is as relevant to you as possible. It works by showing you ads that are based on your browsing patterns and the way you have interacted with the website. It then shows you ads which we believe may interest you.

When you browse the website, some of the cookies and similar technology we place on your device are advertising cookies, so we can understand what sort of pages you are interested in. We can then display advertising on your browser based on these interests.

We only use device information for this purpose, we do not collect or use information such as your name, email address, postal address or phone number for personalized online advertising.

We may also share online data collected through cookies and similar technology with our advertising partners. This means that when you are on another website, you may be shown advertising based on your browsing patterns on the website. We may also show you advertising on the Website based on your browsing patterns on other sites, that we have obtained from our advertising partners.

Online retargeting is another form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with a site away from the website.

For example, if you have visited the website of an online clothes shop, you may start seeing ads from that same shopping site displaying special offers or showing you the products you were browsing. This allows companies to advertise to you if you leave their website without making a purchase.

We also use personalized online advertising to promote our own products and services. This means that you may see advertising for our products and services on the website and when you are on other, third party websites, including social media platforms.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at

http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by: 

FACEBOOK - https://www.facebook.com/settings/?tab=ads 

GOOGLE - https://www.google.com/settings/ads/anonymous  

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info.

Information We Collect:

We may collect different types of personal information, including:

  • Contact information, such as first and last name, telephone number, and address
  • Billing information, such as credit card number and billing address
  • Information necessary to verify your identity
  • Other information necessary to provide you with our products and services

We may aggregate and/or irreversibly de-identify data collected in connection with our products and services and use it for any purpose, including product and service development and improvement activities.

When you visit our website, we will collect and process all or some of the following personal information about you:

Device Information

We automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the website. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

“Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Website.

Order Information

When you make a purchase or attempt to make a purchase through the Website, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers and/or PayPal account information), transaction details (i.e. what product you purchased and when), email address, and phone number. We refer to this information as “Order Information.”

Contact / account information
If you contact us using the website or any of our social media pages, we will receive your name, email address and any other personal information you choose to provide us within your correspondence. If you sign up for an account on the website, we will receive your name, email address and chosen password. We retain your password so that we can confirm your identity for future logins.

Our Privacy Principles:

1. We are accountable to you
CTC USA is responsible for all personal information in its custody and under its control, including any personal information that is transferred to third parties for processing, storage or other purposes. To achieve this objective, CTC USA has developed and implemented this Privacy Policy as part of our overall privacy framework.

2. Why we collect your personal information
CTC USA identifies the purpose for which your personal information is collected. We do this before or at the time the information is being collected. We may collect, use and disclose your personal information in order to:

  • process and administer your payment for the purchase of products or services, if you purchase online or use a debit or credit card for the purchase in one of our stores;
  • process your application for a product, provide a service, or administer the Canadian Tire loyalty reward program or other loyalty or preferred customer programs that may exist from time to time (each a “Loyalty Program”);
  • better understand your product and services needs and to offer relevant information, products, services, rewards and programs to meet those needs, including sending you (and others on your behalf) communications by way of postal mail, e-mail, facsimile, telephone, text message, or other type of electronic message;
  • determine your interest and eligibility for, and where appropriate, provide you with, products, services, rewards and programs;
  • administer the delivery, return or exchange of products, services, rewards and programs to you;
  • track and analyze your purchases, other transactions, shopping patterns, account activity, and payment history for marketing purposes or tailoring promotional offers to you;
  • track and analyze website use to provide a better customer experience such as customized offers and advertisements;
  • conduct surveys and analysis for research, statistical and product development purposes (information will be de-identified to the extent possible);
  • verify your identity and protect against error and fraud;
  • manage and assess our risk;
  • assess and update your credit-worthiness on an ongoing basis;
  • process, service, analyze and audit your relationship with us, including collecting any money you owe us;
  • support promotions and contest administration;
  • perform tests to implement or modify systems;
  • comply with applicable legal, regulatory and self-regulatory requirements;
  • process and respond to your application for employment;
  • respond to your questions, comments or requests to customer service; and
  • achieve other purposes as may, from time to time, be permitted or required by law.

We may also collect contact information about your friends and family members when you participate in one of our refer-a-friend programs. In these instances, we may send a message to your friend or family member on your behalf. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the message from you. Where you are providing us with personal information for other individuals, you agree to provide this notice to them.

By providing your information to CTC USA, you consent to CTC USA using your personal information for the purposes outlined above.

Withdrawal of consent to collect, use and disclose your personal information may restrict our ability to provide you with some products and services, such as receiving communications about promotions, new products or other news.

3. We obtain your consent to collect, use or disclose your personal information
CTC USA obtains your consent to collect, use or disclose your personal information, except as otherwise permitted by law. The method of obtaining consent may depend on the circumstances and the sensitivity of the information. Consent may be oral or written, express or implied. Your express consent (verbal, written or electronic agreement) is generally obtained to collect, use or disclose sensitive personal information.

Benefits you receive through consent
CTC USA is a growing network of interrelated businesses offering a unique mix of products and services. We want to give you exceptional customer service and additional value which is facilitated by sharing your information within CTC USA, Canadian Tire and across our various businesses. This sharing enables us to better understand our customers, notify current and new customers of products, services, rewards and special offers they might enjoy. We may also provide your personal information to CTC USA affiliates or other third-party marketing partners (“Marketing Partners”), including under a Loyalty Program, so that they can notify you directly of products, services, rewards and special offers that may be of interest to you. These notices may be given to you by postal mail, e-mail, facsimile, telephone, text message or other form of electronic message using the contact information that you provide to us.

 “Opting-out” or withdrawing your consent
If you decide that you do not want to receive marketing offers for products and services, you may always withdraw or refuse your consent by clicking on the unsubscribe link in our email communications or by contacting us as set out in Contact Information, below. Your request will be promptly processed but may not be in time to remove you from promotions already in progress. Please note that even if you have opted out of receiving marketing communications, we may still contact you for purposes of administering your account and sending you transactional or operational messages.

The consequences of withdrawing or refusing consent
If you decide to withdraw or refuse your consent, our ability to communicate with you may be diminished. For example, we will generally not be able to tell you about price discounts, rewards, customized balance transfer offers, contests, or other products and services that may be of value to you.

4. We regulate collection of your personal information
CTC USA collects the information as outlined in this Privacy Policy. If the personal information we require is collected for a reason other than as outlined in this Privacy Policy, your consent will be obtained before or at the time the information is collected or as otherwise permitted by applicable law. CTC USA will collect personal information by clear, fair and lawful means.

5. We restrict use, disclosure and retention of your personal information
CTC USA uses and discloses your personal information for the purposes for which it was collected, except with your consent or as otherwise required or permitted by applicable law. We do not sell or rent personal information.

We may transfer your personal information to entities outside CTC USA, such as our vendors, suppliers and agents who assist us in serving you (“Service Provider”). When your personal information is transferred to a Service Provider, we require them to protect the information in a manner that is consistent with this Privacy Policy. Our Service Providers may be located outside of Canada and the U.S. and may be required to disclose your personal information under the laws of their jurisdiction. You may contact us for information about our policies and practices regarding Service Providers to whom we have transferred your personal information and their locations (see Contact Information, below). CTC USA retains your personal information as long as it is required for our business relationship or as required by law.

In the event that CTC USA, any of its affiliated companies, brands or substantially all of their assets are acquired by an unrelated third party, your personal information may be one of the transferred assets. By providing your personal information to us, you agree that we may disclose your personal information, on a confidential basis, to any prospective transferee and its professional advisors for the purposes of their due diligence investigations, the completion of any such transaction and the continued operation of the acquired business.

CTC USA, our various businesses within the Canadian Tire family of companies and Service Providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

6. How we protect your personal information
The security of your personal information is important to us. We have implemented reasonable technical, physical and administrative safeguards and security measures designed to protect your personal information. All of our Service Providers are required under their contracts with us to maintain your confidentiality and may not use your information for any unauthorized purpose. When we are required by law to provide information, we take reasonable steps to verify the lawful authority for the collection and we disclose only the information that is legally required.

We review our procedures and security measures regularly to ensure that they are properly administered and remain effective and appropriate for the sensitivity of the information. However, because no securitymeasure is 100% effective, unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information about you at any time, and to the extent permitted by applicable law, we bear no liability for uses or disclosures of personal information or other data arising in connection with theft of the information or other malicious actions.

7. We are open about our privacy practices
We are committed to providing you with understandable and easily available information about our policies and practices related to management of your personal information.

8. Your rights and choices
You may have the right to access and correct your personal information as described below. Individuals in certain jurisdictions may have certain additional rights and choices regarding our processing of their Personal Information.

  • We keep your personal information accurate. We want to keep your personal information up-to-date, accurate and relevant for its intended use. We rely on you to let us know if your address, telephone number or other information you provide us changes, so that we may provide you with the best possible service.
  • You can access your personal information stored by us. You have the right to access, review, and request changes to your personal information in our custody or control. To access your personal information, a request must be submitted in writing to us (see Contact Information below). We will respond to your request for access or information or changes in a reasonable time.
  • Deletion of personal information: You may request that we delete your personal information. We may reject your request, as permitted by applicable law.
  • Do Not Sell My Personal Information: While we do not sell your information, you may have the right to direct us to stop selling your personal information depending on the jurisdiction in which you reside.
  • Portability: Under certain conditions, you may request that we transfer your personal information to another entity in the format in which we maintain it in the ordinary course of business.

There may be times when we are unable to fulfill your request - for example, if providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we are unable to separate your data), or if we are prohibited by law from disclosing the information. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

9. We respond to your questions, concerns and complaints about privacy
CTC USA or its authorized agent responds in a reasonable time to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures. We will investigate and respond to any concern you have regarding the handling of your personal information. In most cases, an issue can be resolved simply by telling us about it and discussing any issues.

10. Children’s Privacy
CTC USA does not knowingly collect personal information from children under 13. If you have reason to believe that a child has provided personal data to us, please contact us, and we will endeavor to delete that information from our databases.

The website is not intended for individuals under the age of 18 years.

Data Retention:

Our retention periods for personal information are based on business needs and legal requirements. We retain personal information only for as long as is necessary for the processing purpose(s) for which the information was collected. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal information is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.

Changes:

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. If we change this Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will communicate the changes to you.

Contact Information:

You may contact us:

  • by e-mail at privacyoffice@cantire.com
  • by mail at 2180 Yonge Street, P.O. Box 770, Station K, Toronto, ON M4P 2V8- Re: Privacy Inquiries  

If your questions, concerns and complaints have not been resolved to your satisfaction or if you have further questions, you can contact Canadian Tire's Chief Privacy Officer by mail at: Chief Privacy Officer c/o Canadian Tire Corporation, Limited, 2180 Yonge Street, P.O. Box 770, Station K, Toronto, ON M4P 2V8 or by email at privacyoffice@cantire.com.