What Personal Information Do We Collect?
Information we collect directly from you: FGF brands collects Personal Information from you only when you voluntarily submit such Personal Information and only (1) in connection with additional information requests or suggestions submitted by You, (2) during voluntary registration by You, (3) during certain special promotions, contests or survey registrations, (4) in connection with information entered by you as part of a product inquiry or other input process, and (5) in connection with employment applications.
We may collect some or all of the following information directly from you:
- your name
- your mailing address
- your telephone number
- your e-mail address
- details of your inquiries or requests
- products you have purchased (if you are making an inquiry about a product you have purchased)
Information we automatically collect: The nature of the Internet is such that Web servers automatically collect certain information about a visit to a website through cookies, web beacons, and other technologies, including log files, IP address, app identifier, advertising ID, location info, browser type, operating system, device type, domain name, type of computer or mobile device, the website that led you to our Site, the website to which you go after leaving our Site, the dates and times you access our Site, the length of time you visit or use our Site, and the pages you view and links you click and your other activities within the Site.
IP Addresses: IP addresses are unique numbers assigned by Internet Service Providers (ISP) to all devices used to access the Internet. Web servers automatically log the IP addresses of visitors to their sites. The IP address, on its own, does not identify an individual. However, in certain circumstances, such as with the co-operation of an ISP for example, it could be used to identify an individual using the site. For this reason, FGF Brands considers the IP address to be personal information, particularly when combined with other data automatically collected when a visitor requests a Web page such as the page or pages visited, date and time of the visit. In cases where services are provided by organizations outside of FGF Brands websites, such as social media platforms, search or mobile applications, IP addresses may be recorded by the third-party service provider.
We may use various technological methods to track the patterns of users accessing and using our website and mobile apps, including the following methods:
Web Beacons, clear GIFs, pixel tags and other technologies: Web beacons (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use these technical methods to analyze the traffic patterns on our site, such as the frequency with which our users visit various parts of our site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send to determine whether you have opened those e-mails or clicked on links in the e-mails. The information from use of these technical methods may be collected in a form that is not personally identifying.
Click Stream Data: When you use, read, browse or download information from our website and apps, we or our service providers may also collect information such as the date, time and duration of a visit, information about your location, the pages accessed, the IP address of your computer, and any information downloaded.
Users may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance of Canada (“DAA Canada”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA Canada companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page, or if you are in the United States, the Digital Advertising Alliance’s Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI or DAA members.
Opting out from one or more companies listed on the online advertising industry websites identified above will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our site or apps or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the online advertising industry websites, your opt out may not be effective. Additional information is available on the DAA Canada’s website at http://youradchoices.ca/ or the NAI’s website at www.networkadvertising.org, or the DAA’s https://youradchoices.com/.
For What Purposes Do We Collect and Use Personal Information?
Regardless of the purpose for which Personal Information is submitted, it is FGF’s policy to maintain all Personal Information as confidential and to collect, use and disclose such Personal Information for the following purposes:
- to contact you in response to your inquiries, comments and suggestions;
- to contact you otherwise when necessary;
- for the specific purpose for which it was volunteered (for example, to receive notice from us, etc.);
- to track our visitors’ use of the Site for internal market research;
- to operate, maintain and improve the Site and the services FGF promotes or provides through the Site;
- to provide and administer products and services you request, and to disclose the information for any purpose related to the provision of requested products and services;
- to provide personal information to suppliers of products and services (as discussed in more detail below);
- to customize the content and/or layout of our Site for each individual visitor;
- to notify visitors about updates to the Sites or Services;
- to generate aggregate statistical studies;
- as required by law or regulation, or as requested by government authorities;
- in connection with an acquisition, merger, sale or other transfer of all or part of the business;
- to maintain accurate customer records;
- to protect us, yourself and others from fraud and error and to safeguard our business interests;
- to collect debts owed to us;
- to comply with legal and regulatory requirements;
- to consider your application for employment at a FGF company;
- for other legitimate business purposes of FGF or the Site; and
- to distribute to parties including financial institutions, payment processors, lawyers, financial institutions and government licensing bodies for any of the above purposes.
The collections, uses and disclosures listed above are a reasonably necessary part of your relationship with us. We may also collect, use and disclose your Personal Information as follows:
- to ask for Your participation in brief surveys;
- to notify You about promotions, special offers, etc., regarding products and services provided by FGF or its affiliates or partners; and
- with your consent, to share your Personal Information with suppliers and third parties so that they may offer their products or services to you.
These uses and sharing of your Personal Information is at your option, and you may instruct us not to use or share your Personal Information for these purposes at any time by providing written notification to us at the contact information set out below. We will not refuse you access to any product or service merely because you have instructed us to stop using or sharing your Personal Information in these ways.
How Do We Share Your Information?
Service Providers: We may retain agents, subcontractors or service providers from time to time in relation to our business or the products or services that we provide. If we require a service provider to deal with your personal information, we will take reasonable steps to ensure that the service provider adheres to privacy procedures and will keep your personal information confidential. We will not provide more information than is necessary to the service provider and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.
Our service providers may be located outside of Canada, and you acknowledge that personal information may be processed and stored in foreign jurisdictions with different privacy laws, and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction.
We will obtain your consent to collect, use or disclose Personal Information except where we are authorized or required by law to do so without consent. Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your Personal Information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of withdrawal of consent. If you notify us that you withdraw consent, we will inform you of the likely consequences of that withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.
Limits on Collection of Personal Information
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.
Limits for Using, Disclosing and Retaining Personal Information
Your Personal Information will only be used or disclosed for the purposes set out above and as authorized by law.
We will destroy, erase or make anonymous documents or other records containing Personal Information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.
We will take due care when destroying personal information so as to help prevent unauthorized access to the information.
Accuracy of Personal Information
We will make a reasonable effort to ensure that Personal Information we are using or disclosing is accurate and complete. Because you provide much of the Personal Information we collect, we depend on you for providing accurate information.
If you demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
If a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
How Do We Keep Your Information Secure?
We have reasonable and appropriate security measures in place to protect the loss, misuse and alteration of Personal Information under our control. Please be advised, however, that while we strive to protect Your Personal Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction or inadvertent disclosure of your Personal Information.
You have a right to access your Personal Information held by us.
Upon written request and authentication of identity, we will provide you your Personal Information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so (where permitted by applicable law).
In some situations, we may not be able to provide access to certain Personal Information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm our competitive position). We may also be prevented by law from providing access to certain personal information.
If we refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
Additional Information for California Residents
In this section, we provide additional information to California residents about how we handle their personal information, including household information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
A. Categories of Personal Information Under the CCPA (3/1/2021)
While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about California residents in the prior 12 months (from the Last Updated data above).
Categories and Sources of Personal Information Collected. The table below identifies, generally, the categories of personal information (as defined by the CCPA), we have collected about California residents. For more information about the business or commercial purposes for which we collect and use personal information, please see the For What Purposes Do We Collect and Use Personal Information? section above.
|Categories of Personal Information||Description|
|Identifiers||Includes direct identifiers, such as name, email address, phone number, address and other contact information, IP address and other online identifiers.|
|Customer Records||Includes personal information, such as name, contact information and communications that individuals provide us for customer service-related purposes. For example, this may include information collected when an individual contacts us with a customer service request or inquiry.|
|Commercial Information||Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies that an individual provides to us in a customer service communication.|
|Usage Data||Includes Site browsing history, clickstream data and other usage data and information regarding an individual’s interaction with our Sites and our marketing emails and online ads.|
|Inferences||Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.|
Sources of Personal Information. As further described in the What Personal Information Do We Collect? section above, we may collect personal information from the following sources:
- directly from the individual
- advertising networks
- data analytics providers
- social networks
- internet service providers
- operating systems and platforms
Disclosures of Personal Information. In the table below, we identify the categories of personal information we have disclosed for a business purpose or “sold” as defined by the CCPA , as well as the categories of third parties to whom we may disclose or sell such personal information. For more information about the business and commercial purposes for which we may disclose and sell (as defined under the CCPA) personal information, please see the How Do We Share Your Information? section above. Under the CCPA, a “sale” includes disclosing or making available to a third party personal information, in exchange for monetary compensation or other benefits or value. While we do not disclose personal information in exchange for monetary compensation, we may make certain categories of personal information available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party cookies and tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content.
|Categories of Personal Information||Do We Disclose for a Business Purpose?||Do We Sell?||Categories of Third Parties to Whom Information is Sold or Disclosed|
B. California Residents’ Rights
CCPA Rights. In general, California residents have the following rights with respect to their personal information:
- Do-not-sell (opt-out): to opt-out of our sale of their personal information. California residents may opt out of sales of their personal information by us, by submitting a request to firstname.lastname@example.org.
- Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
- Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
- categories of personal information collected;
- categories of sources of personal information;
- categories of personal information about them we have disclosed for a business purpose or sold;
- categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
- the business or commercial purposes for collecting or selling personal information; and
- a copy of the specific pieces of personal information we have collected about them.
- Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. California residents may submit CCPA requests to opt out of sales, requests to know (access) and requests to delete their personal information through one of the following methods:
- Email email@example.com
- By phone at 905-761-3333
In addition, California residents may opt of “sales” of their personal information by us by using our preference manager OneTrust.
When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number). In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual [by contacting us firstname.lastname@example.org]; authorized agents will be required to provide proof of their authorization and we may also require that the relevant California resident directly verify their identity and the authority of the authorized agent.
For more information about our privacy practices, you may contact us as set forth in the Contact Us section below.
C. California Do Not Track Notice
Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to web browser Do Not Track signals. In addition, we may allow unaffiliated parties to collect personal data from your activity on our website, as described above.
D. California Shine the Light Disclosure Information
Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address specified below under “Contact Us”. The request should attest to the fact that the requester is a California resident and provide a current California address. Please note that we are required to respond to each customer only once per calendar year.
If you are a California resident and would like to request that we do not disclose your personal data to third parties for direct marketing by such third parties, you can exercise your right to prevent such disclosures at no cost to you by contacting us as set forth below.