PRIVACY POLICY

We, Elesa Canada Ltd. (“Elesa”) appreciate your interest in our products and services. Elesa recognizes the importance of your privacy. For the purposes of this Privacy Policy (the “Policy”), the terms “Elesa,” “we,” “us,” and “our” refer to Elesa and all of its subsidiaries and affiliates. “You,” or “your” refers to you, as a user of our website ( https://www.elesa.com/en/elesab2bstoreca ) and services, whether operated by us or on our behalf (the “Services”).

This Policy describes Elesa’s collection, use, processing, disclosure and retention of your personal information and informs you on how to opt out of certain uses of your information. By accessing Elesa’s website and the use of the services provided, you consent to the collection and use of certain personal Information as further described in this Policy. Personal information means any information relating to an identifiable person, including information that you provide to us and information that we may collect through your use of the Services.

This Policy regarding how personal information entrusted to us is collected, used, processed, disclosed and retained reflects the principles set forth in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).

It is important that you read this Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing your personal information so that you understand how and why we are using your data. This Policy supplements those other notices and is not intended to override them.

BY VISITING OUR WEBSITE, USING THE SERVICES, SUBMITTING INFORMATION AND/OR PURCHASING ANY PRODUCTS, YOU CONSENT TO THE COLLECTION, USE, PROCESSING, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS POLICY. THEREFORE, BEFORE YOU PROVIDE US WITH ANY PERSONAL INFORMATION, YOU SHOULD READ THROUGH THIS POLICY IN ITS ENTIRETY AND UNDERSTAND ITS TERMS. IF YOU DO NOT AGREE WITH THIS POLICY, YOU SHOULD NOT VISIT OUR WEBSITE, USE THE SERVICES OR OTHERWISE PROVIDE INFORMATION TO US.

We may update the Policy from time to time. It is your responsibility to check this Policy from time to time to ensure that you are up to date with any changes. This Policy is incorporated into, made subject to and is governed by, that certain Terms and Conditions (“Terms”) by and between us and you. By continuing to visit our website and use the Services after changes are made to this Policy, you agree to be bound by the revised terms.

Our Services are directed at users in Canada. If you are not a resident of Canada, please refer to your Country website or to the Worldwide version.

THE SERVICES ARE INTENDED FOR ADULT USE ONLY AND ARE NOT DIRECTED TOWARDS CHILDREN, MINORS, OR ANYONE UNDER THE AGE OF 18. YOU MUST BE 18 YEARS OF AGE TO USE THE SERVICES.

• 1. Overview of Our Privacy Practices

  The purpose of this Policy is to inform you of our privacy practices and policies, including:

  • what information we collect and why we collect it;
  • our privacy practices and how we use your personal information;
  • who we share your information with;
  • your rights with respect to your personal information; and
  • who you can contact should you have questions or concerns about our privacy practices.

  Overview of Our Privacy Practices

  Our privacy practices are summarized here. Under this Policy, we:

  1. collect personal information when you visit our website, use the Services or otherwise correspond with us, for the purposes outlined in Section 3 of this Policy;
  2. collect non-identifiable aggregated data regarding users and activity on our website for research, marketing and analytics purpose;
  3. use, share and disclose the information collected by us, in accordance with this Policy, including with third party service providers we engage to provide certain services on our behalf. Such third parties may only use personal information you provide to us for the purposes you have consented to within this Policy;
  4. retain your personal information in compliance with our legal obligations and only as long as necessary for the purposes of which it was collected; and
  5. store your personal information on our servers in Canada and may transfer, process and store your personal information with our affiliates or on the servers of third party service providers that we or our affiliates engage outside Canada. However, third party service providers are permitted to store, process and access your personal information only in accordance with the purposes set out in this Policy or as required by applicable law;
  6. allow you to withdraw your consent to the collection, use, processing and/or disclosure of your personal information at any time; and
  7. mitigate the risk and impact of potential harms to you by using reasonable physical, technical and organizational procedures appropriate to the sensitivity of the information in an effort to safeguard your personal information. Even with these measures, there is a residual risk of the loss of, unauthorized access to, or unauthorized disclosure of your personal information which could result in financial or other harm to you. In addition, there is a risk that your personal information may be accessible to law enforcement or regulatory agencies outside Canada.

  
  

  Further information with respect to our privacy practices is set out below.

• 2. What Information We Collect and How We Collect It

  Elesa collects certain information about you during your interactions with our Services.

  • a) Information You Voluntarily Provide

    You may give us information, including your personal information, by filling out forms, registering for an account with us, purchasing our products, or corresponding with us by mail, phone, email, or otherwise. This includes information you provide when you:

    1. register for an account with us;
    2. use the Services (such as requesting for information or contact, technical drawings or catalogues request services);
    3. purchase our products, place orders using our Services or shop with us; or
    4. request marketing materials to be sent to you.
    5. share your cart with another person, together with a specific message, using Cart Sharing Service.
    
    

    Here are the types of information we collect about you:

    • Identity and Contact data. We collect your contact information, e.g. last name, first name, e-mail address, company name, telephone number and login data;
    • Purchase Data. We may offer the option to purchase produces or services, in which case we will collect data related to online purchases of products or services such as shipping address and billing address;
    • Location data.We may collect data on your location in order to provide precise and useful services, including asking you to enter your address or postcode; and
    • Other Information You Volunteer. We may collect any other information you voluntarily provide to us in the course of your communications with Elesa.
  
  

  • b) Information We Collect When You Use Our Services

    When you use our Services, we may collect the following types of information.

    • Automated technologies or interactions. As is true of most websites, we receive and store certain types of personal information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
    • Browser data. We may collect information from your Internet navigation software (“Browser”). Your Browser may share an approximation of your geographic location through information on wireless access points close to you and on your device internet protocol (IP) address, information on browsing history and other data relating to your use of the Browser.
      Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. The website do not currently provide this kind of setting. For more information about DNT signals, please visit http://allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
    • Information Collected by Cookies set on the site as further described in the Cookie Policy and Other Technologies. We may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. If you remove or reject cookies, it could affect the availability and functionality of our Services. For more information about cookies, please visit: www.allaboutcookies.org.
  
  

  • c) Information We Collect in Aggregated Form

    We may collect, use and share aggregated data such as statistical or demographic data for research, marketing and analytics purposes. Aggregated data may be derived from your personal information but is not considered personal information as the aggregated data has de-identified the information so that the data cannot directly or indirectly reveal your identity. However, if we combine or connect any aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Policy.

  
  

  • d) Information We Collect From Third Parties

    We collect personal information about you from various third parties, including those listed below. The collection, use, and disclosure of personal information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user.

    • Third Party Service Providers. We collect personal information from service providers including where we operate accounts on third-party platforms, such as online application submission and management platforms and email platforms.
    • Third Party Advertising Partners. We collect personal data received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
    • Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles aggregate data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
  
  

• 3. Why We Use Your Personal Information

  Our primary purpose for collecting personal information is to provide you with products and services you request. We may also use your personal information for the following business purposes:

  • to provide you with information, products and/or services you request;
  • to communicate with individuals in written, electronic, and verbal form;
  • to manage our customer relationship with you;
  • to obtain payment for services and products that we may provide to you;
  • for our internal marketing purposes, which include, but are not limited to, sending you promotional or marketing information about our products, services, updates, etc. that we think may be of interest to you, if you have consented to receiving such communications from us;
  • to customize the advertising and content you see;
  • to send promotional newsletters or catalogues if you opted to receive such communications from us;
  • for internal business purposes such as complying with our internal policies or improving our Services;
  • to analyze how our Services are being accessed and used;
  • to verify information when you register or create an account with us;
  • to protect our interests, including establishing, exercising and defending legal rights and claims;
  • as necessary to comply with legal requirements, to enforce our terms and conditions (such us Terms and Conditions of Use) and to prevent fraud, co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities; and
  • for any other purpose for which you have provided your consent or as otherwise set forth in this Policy.

• 4. How We Share Your Personal Information With Third Parties

  Your personal information is retained in confidence and it is only shared with our authorized employees, agents, partners, affiliates, service providers and legal representatives. Such persons may only use your personal information for the purposes you have consented to within this Policy.

  Third parties who may receive your personal information are:

  • Service Providers. We may use third-party service providers to perform certain business services on behalf of us or the Service, and may disclose personal information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the personal information to provide these services and are prohibited from selling personal information. Business services provided include, but are not limited to, hosting services, document management services, communications services, software and website development services, collection services, accounting and audit services, compliance services, quality control services, and analytics services.
  • Marketing and Fulfilment Services. Elesa may, without providing further notice, share your personal information with: (a) third party vendors that provide services on behalf of Elesa for the sole purpose of providing you with the information and/or Services discussed in this Policy; and (b) third party vendors that provide marketing and other services on behalf of Elesa. However, any such third party will not be authorized to sell, rent, trade, or otherwise use your personal information outside of the terms and conditions described in this Policy.
  • Internal Third Parties. We may share personal information with our parent company, subsidiaries and other companies owned by or controlled by Elesa who may use the personal information for the purposes described above and in accordance with this Policy.
  • Business Transactions. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Policy.
  • Legal Process. Subject to applicable law, we may disclose personal information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
  • Non-personal and Aggregate Information. Elesa uses aggregated data that does not identify any specific individual to improve the design of this website and may share it with marketing and advertising agencies for this purpose. Any such information may be gathered through cookies, pixel tags, click-stream information as discussed above.

• 5. How We Protect Your Information

  Elesa uses reasonable physical, technical and organizational procedures appropriate to the sensitivity of the information in an effort to protect it from alteration, misuse, loss or destruction. Internal access to personal information will be limited to individuals who need access to personal information in order to provide products and/or services or to maintain those products and/or services. Individuals having access to personal information are limited in number and committed to Elesa’s privacy and security policies.

  It is important to remember that no method of transmitting or storing data is completely secure. Data transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicate or transmitted. Therefore, even though Elesa endeavors to protect personal information, security of any information you transmit to Elesa, or that you may receive from Elesa, cannot be guaranteed.

  In order to prevent unauthorized access to your account and personal information, Elesa recommends selecting and securing login data and passwords properly and limiting access to computers, devices and browsers used to communicate with our website. Always log out after using the website.

• 6. Where We Store Your Information

  We store and retain your personal information in compliance with this Policy. Your personal information is stored on our servers in Canada and we may transfer, process and store your personal information with our affiliates, including Elesa S.p.a. at its headquarters in Italy (for the purposes of proper management of the website and the Services). We or our affiliates may also engage third party service providers with servers in locations other than Canada and Italy to process and store your personal information.

  As such, foreign governments, courts, law enforcement or regulatory agencies may be able to access your personal information under foreign laws. However, our affiliates and such third-party service providers are only permitted to store, process and access your personal information, and are not otherwise authorized to collect, use or disclose your personal information, except in accordance with the purposes set out in this Policy or as required by applicable law.

• 7. How Long We Keep Your Information

  We will retain and use your information as long as necessary for the purposes of which it was collected, including as necessary to provide services to you, maintain a record of your transaction(s) and progress for reporting purposes, comply with our legal obligations, to resolve disputes and to enforce our agreements. Personal information that is no longer required will be securely destroyed, erased or made anonymous according to our guidelines and procedures. As such, we may retain your information in an anonymized form for analysis, research, and marketing purposes.

  For further details on our data retention periods, please contact us using the information provided in Section 12 below.

• 8. Your Rights and Access to the Information We Collect

  You may request details of personal information which we hold about you. We will make available upon request all personal Information we have on file about you and we will correct, amend or delete information upon request. If you would like a copy of the personal information we have on file about you, please contact us using the information provided in Section 12 below.

  You can request from us information about:

  • the personal information we hold about you;
  • the categories of personal information concerned;
  • the purposes of the processing;
  • details to whom your personal information has been/will be disclosed;
  • how long we retain your personal information;
  • if we did not collect the information directly from you, information about the source; and
  • how to lodge a complaint with the correct supervisory authority.

  You may also request that we:

  • update any incomplete or inaccurate information about you; or
  • delete your personal information in accordance with applicable laws.

  Under certain circumstances, it is possible that we may not be able to provide you with all of the information you may have requested. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Fees may be applied to any copy of the requested information. We will provide the reasons for denying access upon request.

• 9. Updating Your Information

  It is your responsibility to notify us of any changes to your personal information, including contact information, so we can contact you and inform you with respect to your use of the Services. If your personal information becomes out of date or is incorrect, please contact us as soon as possible using the information provided in Section 12 and we will correct any information found to be incorrect. Failure to inform us of such changes is a breach of our Terms and Conditions of Use and may result in suspension or termination of the Services.

• 10. Withdrawal of Your Consent

  You may withdraw your consent to the collection, use, processing and/or disclosure of your personal information under this Policy at any time, subject to legal and contractual restrictions and reasonable notice. To do this, you may contact us using the information provided in Section 12. Please note that if you withdraw consent you may not be able to continue accessing our Services, using our website or certain features of it.

  In the event you have previously consented to be added to our mailing list to receive marketing materials, such as our promotional newsletters or catalogues, and prefer not to receive such communications from us, simply contact us using the information provided in Section 12 below and we will remove you from such list.

• 11. Amendments to this Policy

  Elesa reserves the right to amend or supplement this Policy at any time and without prior notice. Amendments will take effect immediately after implementation. Your continued access to this website will be considered as acceptance of any such amendment or supplement. Therefore, you are encouraged to review our online privacy whenever you visit this website for the most current version.

• 12. Our Contact Information

  In the event that you may have any questions regarding Elesa and this Policy you may send us an e-mail at info@elesacanada.com. To review or update your personal information in our possession, to withdraw consent for the collection, use, processing and/or disclosure of your personal information or remove your e-mail from our mailing list, please contact us at the above e-mail or at the address below:

  Peter Anderton - panderton@elesausa.com