Scope and application
Definition of “personal information”
What type of personal information does Principal collect and how?
Principal limits the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. Principal collects personal information directly from you, from other sources, through online technologies (such as when you are interacting with us through the Site) or otherwise with your consent or as required and/or permitted by law. Principal collects personal information in the following ways:
Directly From You
You may provide personal information to Principal by mail, by email, over the telephone, through the Site or in any other direct manner.
Principal collects the information you provide when you contact Principal with an inquiry, contact customer service (including through the chat feature on the Site), complete a satisfaction survey or contact Principal through social media.
Principal collects the information you provide when you create an account on the Site or sign up for a newsletter and when you make a purchase.
Principal collects information about your transactions on the Site, for instance when you make a purchase.
From Other Sources
Occasionally, Principal may receive personal information from other sources. In these cases, Principal receives your personal information from these other sources with your consent or if the law requires or permits Principal to do so.
Principal collects information about your transactions on the Site, for instance when you make a purchase.. Principal may collect certain types of information electronically when you interact with the Site, emails, social media accounts, online advertising, or through technologies. This information helps Principal understand what actions you take on the Site and allows the Site to work correctly.
Principal may use information about your purchase on the Site to provide you with interest-based advertisements based on your purchasing profile; and
Principal may collect, combine and categorize your personal information on an aggregated basis to identify purchasing patterns to help it analyze its business activities in order to better serve customers.
The technologies and services used by Principal include:
Cookies, which are small text files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit the Site.
Web beacons, and single pixel gifs, which are small image files that have information about you, such as your IP address, that can be downloaded when you visit a website or open an e-mail. This allows Principal to understand your online behaviour, monitor its email delivery, and provide you with interest-based advertising. These tools also allow Principal’s third-party tracking tools to gather information, such as your IP address, and provide this back to Principal in an anonymized, aggregate form (i.e. in a manner that prevents it from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
Other technologies, such as analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization, interest-based advertising, customizing content and other methods to gain insights into Principal’s customers’ needs and preferences. For instance, Principal uses Google Analytics which allows it to see information on user website activities including, but not limited to, page views, source and time spent on the Site. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt out of Principal’s use of Google Analytics by visiting the Google Analytics opt-out page.
Through these technologies, Principal may collect personal information as follows:
Third-Party Social Networks.
Principal uses Google Ads Remarketing to advertise Principal across the Internet and to advertise on third-party websites (including Google) to previous visitors to the Site. Google Ads remarketing will display ads to you based on what parts of the Site you have viewed by placing a cookie on your web browser. It could mean that Principal advertises to previous visitors who haven’t completed a task on the Site or this could be in the form of an advertisement on the Google search results page, or a website in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on the Site, so that they may show you ads relating to that page. If you do not wish to participate in Principal’s Google Ads Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.
Online Interest-based Advertising.
You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on the Site.
How Principal uses personal information?
Principal may use your personal information to provide you with its products, programs and services, to manage its business operations, to communicate offers and information it thinks might interest you, to generally enhance your customer experience, and as otherwise permitted or required by law. Principal uses your personal information with your consent or as permitted or required by law, and for the following purposes:
Providing the Products, Programs and Services you Request Principal may use your personal information in order to provide its products, programs or services, for instance:
to process and fulfill your purchases;
to process and answer your inquiries or to contact you in order to answer your questions and/or requests;
to enable your participation in contests, promotions, surveys or chats, as applicable;
to manage your registration to Principal’s newsletters or other communications;
to determine your eligibility for a product or service;
to take instructions from you;
to create, administer, and maintain your account.
Managing Commercial Activities Principal may use your personal information to manage its business, for instance:
to authenticate the identity of individuals contacting Principal by telephone, electronic means or otherwise;
to notify you of changes to your account or the Site’s services, terms, conditions or policies and to provide you administrative messages, updates, legal notices, technical notices or security alerts;
for internal training and quality assurance purposes;
to deploy and manage its information technology applications and systems, including managing the Site;
to manage and facilitate the use of the Site, which may include using cookies and other similar technology;
to protect Principal and third parties from errors and fraud;
to monitor and investigate incidents and managing claims;
to maintain Principal’s commercial activities;
to meet Principal’s contractual, legal and regulatory obligations.
Marketing and Advertising
Principal may use your personal information to market its brands and products, which it believes may be of interest to you. Principal uses your personal information to place you in general interest and purchase categories, which helps it determine what types of advertisements may be of interest to you and then serve you with these advertisements. Principal may draw inferences from items you purchase online and use these inferences to gain insights into how well its products sell to a certain general interest group. Principal may conduct marketing and advertising in a variety of ways:
by communicating with you by email, telephone, or direct mail;
by delivering advertisements relevant for you on the Site;
by customizing the content you see on the Site; and
by providing personalized products and communications as well as product recommendations to customers.
If you no longer wish to receive commercial electronic messages, please follow the unsubscribe directions provided in every commercial electronic message.
Conducting Market Research and Data Analytics
Principal may use your personal information in order to conduct market research and data analytics by tracking and analyzing current or previously collected information for the following purposes:
to improve or develop new products, services, programs, promotions, contests or events, and to better understand its customer base and behaviour;
to manage and develop its business and operations;
to improve its products, the Site and other programs or services it may offer;
to understand customer needs and preferences and customizing how it tailors and markets products, programs and services to its customers based on their interests;
to measure the effectiveness of its marketing; and
to understand how visitors interact with the Site and ensure they work correctly.
When possible, we will use your information in an aggregated and/or de-identified format.
How Principal shares personal information?
Principal may hire service providers, which may be affiliates, to perform services on its behalf. This may include, without limitation, a person or an organization retained by Principal to perform work on its behalf, including for marketing research, customer service and web-related services, and quality control assessment. Principal provides them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. For example:
Personal information collected from contest participants may be shared with Principal’s contest administrator to contact selected winners.
Personal information may be disclosed to Principal’s accountants, auditors, agents and lawyers to enable it to make informed decisions with respect to its rights and obligations.
Sale or Transfer of Business or Other Transaction
Principal may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, reorganization or financing of parts of its business (including the proceedings of insolvency or bankruptcy). In the event the transaction is completed, your personal information will remain protected y applicable privacy laws. In the event the transaction is not completed, Principal will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information, in compliance with applicable laws.
Other Permitted Reasons
From time to time, Principal may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. Principal may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Principal also reserves the right to report to law enforcement agencies any activities that it, in good faith, believes to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. Principal may release certain personal information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and itself, in accordance with or as authorized by law.
With Your Consent
Other than the purposes listed above, Principal may, with your implied or express consent, share or disclose your personal information outside of its group of companies, in accordance with applicable laws.
How Principal manages consent?
Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with Principal.
If you choose not to provide Principal with certain personal information or if you withdraw your consent, where such withdrawal is available, Principal may not be able to offer you the products, programs or services that you requested or that could be offered to you.
How can you change your privacy choices?
Principal wants you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences, including, for example: managing your preferences within your account when applicable, at registration or by contacting Principal directly, changing your browser settings on your device, and/or, where available, using third party unsubscribe functionality.
Within Your Account
If you have an account with Principal, you can update your preferences through your account.
At Registration or by Contacting Principal
Directly You may opt in to receiving email marketing communications at the time of registration (for instance, when you create an online account or enter contests or promotions) or any time thereafter through your online account. Principal may also have your implied consent to send you such marketing electronic communications under applicable laws.
You may opt out of:
Receiving email marketing communications by clicking “unsubscribe” within any marketing email you receive; and
Receiving mail or telephone marketing, or quality control communications, by contacting Principal’ customer service or by communicating with Principal using the contact information below.
Please note the following regarding withdrawal of consent or changes in your privacy preferences:
Even if you have opted out of receiving marketing communications from Principal, Principal may still contact you for transactional purposes, in compliance with applicable laws (e.g., for customer service, product information, service or reminder notices, or recalls). Principal may also need to contact you with questions or information regarding your customer service inquiries; and
It may take some time for all of Principal’ records to reflect changes in your preferences (e.g., if you request that you not receive personalized marketing communications from Principal, your preference may not be captured for a promotion already in progress).
Changing Your Browser Settings on Your Device
Principal use technologies to enhance your customer experience and present offers to you, including interest-based advertisements. For example, technologies such as cookies allow Principal to recognize when you use or return to the Site, providing you with a more seamless experience. You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features of the Site.
Please refer to your browser instructions or help screen to learn more about how to block, delete and manage cookies on your computer or mobile device.
Using Third Party Unsubscribe Functionality
Principal may use third parties (e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behaviour as you visit the Site or to provide advertising. Please see the Online Technologies section for information how to manage your privacy preferences with respect these third parties.
You may also control the ads you see on Google and Facebook services in your Google Ads Settings and Facebook Ad Preferences.
How Principal stores and safeguards personal information?
Principal takes the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical and technical safeguards implemented by Principal and its web hosting agency.
How Principal Protects Personal Information
Principal employs organizational, physical and technological measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These measures include access restrictions, encryption, and personnel training concerning the importance of preserving the privacy, confidentiality, and security of the personal information collected. These safeguards also apply when Principal disposes of or destroy your personal information.
Please be careful whenever sending personal information to Principal electronically. Please note that transmissions over the Internet are never completed protected or exempt from error. It is the reason why Principal cannot guarantee the security of the information transmitted electronically since such transmissions are conducted at your risk and peril. More specifically, an email sent to the Site or from the Site cannot be protected. Principal recommends that you keep this in mind when you determine the nature of the information transmitted electronically. Moreover, when you use them, the protection of your login, password and other special access elements of the Site is your exclusive responsibility. Please ensure that they are kept confidential.
Transfer of Personal Information Outside of Canada
Principal may share personal information within Principal’ groups of companies in Canada and with its affiliates and subsidiaries outside Canada. Some of its service providers may also access, process or store your personal information outside of Canada. Principal uses reasonable safeguards, such as contractual requirements, to ensure that its service providers protect your personal information wherever it is used or stored.
As a result, when your personal information is used or stored in a jurisdiction other than Canada, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
How Long Principal Keeps Personal Information
Nous conservons vos renseignements personnels aussi longtemps qu’il est nécessaire de le faire aux fins pour lesquelles nous les avons recueillis, sauf si la loi exige ou permet une conservation différente. Lorsque nous n’en avons plus besoin, nous détruisons vos renseignements personnels de façon sûre ou les anonymisons (de sorte qu’ils ne permettent plus de vous identifier).
It is neither Principal’s goal nor its intention to collect or post personal information concerning persons under the age of majority in their territory of residence without their parent or legal guardian’s consent. Principal does not knowingly provide any personal information collected from such persons, regardless of its source, to any third party for any purpose whatsoever.
Notwithstanding the foregoing, it is possible that Principal nevertheless collects such information if same is provided to it. Principal therefore encourages parents to inform their children about the possible consequences of using the Site and disclosing information through the Site. Principal will not assume any responsibility with respect to the use of the Site or disclosure of information via the Site by children.
MINORS ARE HEREBY REQUIRED TO OBTAIN THE PERMISSION OF THEIR PARENT OR LEGAL GUARDIAN BEFORE PROVIDING ANY PERSONAL INFORMATION TO Principal.
Accessing and correcting your personal information
You have the right to access and rectify the personal information Principal holds about you, subject to any legal restrictions. Upon request, Principal will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.
You can request access or rectification by contacting Principal directly.
Who can you contact with privacy questions?