Form of Consent
When we collect, use or disclose your personal information we will generally obtain your consent. Most of the time, we will obtain your consent before or at the same time we collect your personal information. In some instances, however, we may seek your consent after we have collected your personal information if we wish to make an additional use or disclosure of your personal information where we do not already have your consent for that new use or disclosure.
Depending on the circumstances, your consent may be express or implied. Express consent would arise if you specifically consented to a particular dealing in your personal information. Express consent can be given orally, electronically or in writing.
Implied consent can be inferred from the circumstances and, in particular, where the uses and disclosures are readily apparent at the time we collect the personal information. For example, if you send us an email requesting certain information, we will use the email address in your email to send the requested information to you without asking you if we can use the email address for that purpose; your consent will be implied in those circumstances. As well, we will assume your consent to the collection, use or disclosure of your personal information for a particular purpose if you voluntarily provide the information for that purpose.
The Data We Collect
Requirement to have an Account. In order to use certain features and functionality of the Sites you may need to provide certain personal information including name, current addresses, phone numbers and other contact information. We may issue to you a unique “user id” which you will be required to provide each time you use these features and functionality. If you have a user id, then we may collect information about your use of the Sites (whether or not you provide your user id each time) and we may associate this information with your other personal information.
Anonymous Electronic Information. In general, you can browse the Sites without telling us who you are or revealing any personal information about yourself. However, we collect your computer’s or mobile device’s IP address, which you necessarily disclose when you visit the Sites, so that data (such as the web pages you request) can be sent to your computer or device.
Additional Electronic Information. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of the Sites. During your visit to our Sites, we may record choices you have made and use this to provide more customized content or advertising. This is sometimes called “clickstream” data and does not identify you and is not retained after your visit.
The Sites are not designed to respond to “do not track” requests from web browsers.
Location Information.We may collect information about your location if you provide your address or postal code or we may approximate your location based on your IP address. If you provide our mobile applications access to location services on your device, we and our third-party providers may collect location data through GPS, Wi-Fi, wireless network triangulation or other similar methods.
Voluntarily Provided. We will collect personal information that you voluntarily provide to us.
Through Your Other Interactions with Us. When you interact with us through certain activities on the Sites or in connection with the Services, such as subscribing to our mailing lists, inquiring about a franchise, making an appointment, and sending messages through the Sites, we may ask you to provide personal and other information. In order to engage in such activities, you will be required to provide information that lets us know the specifics of who you are, such as your first name, last name, e-mail address, phone number, and other information. If such information is required to provide Services to you or where it is optional for you to engage in these activities, then if you do not provide the mandatory information with respect to a particular activity, you may not be able to engage in that activity and we may not be able to assist you in connection with our Services or fulfill the purpose for which you contacted us. You may also limit your ability to use all or a portion of the Sites.
Use of the Data We Collect
In Connection with Our Business. We may use your personal information for particular activities, including, without limitation, responding to your inquiries, customer service, providing Services to you, payment processing, collections, marketing and research, sharing your stories that you provide to us, developing and displaying content tailored to your interests, processing your franchise application and contacting you regarding franchise opportunities, providing promotional and other information to you, and contacting you regarding administrative notices or to solicit feedback on your experience with us or one of our franchisees. In particular, set out below are certain circumstances where we may use your personal information without obtaining any further consent:
- using identification information and contact information, such as your name and e-mail address to provide information about us, the Services and Sites when you request that information;
- using identification information and contact information, such as your name and e-mail address so that we can identify you and deliver the Services that you request and to communicate with you regarding those Services;
- using payment method preferences and related financial information that you provide to us so that we can obtain payment for the Services that you request;
- using information relating to your preferences so that we are able to deliver our Services and in connection with the Sites, to you in accordance with those preferences;
- using relationship information such as your service requests, instructions, comments and feed back to assist us in delivering Services, including in connection with the Sites, in accordance with your wishes;
- using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose. For example, if you request a Service from us, we may send you follow up correspondence to ask you about your satisfaction with the Service. Further, we may store your response and use the information in the response when we provide Services to you in the future;
- using your e-mail address to provide you with information about new features or enhancements to the
Services and the Sites;
- analyzing how personal information is being used to assist us in developing and enhancing our Services and the Sites; and
- analyzing how personal information is being used to assist us in conducting market analysis and strategic planning.
Location Information. We may use your location information to provide personalized content and advertising, to enhance your experience with the Sites and Services, to allow you to view promotions and products available to you based on your location, to assist us with analytics, and to improve the effectiveness of our Sites and Services.
For Improving our Sites and Services. We may use your IP address and similar web site use information to: (i) help diagnose problems with the Sites, administer and improve the Sites, and measure the use of the Sites; (ii) identify the type of web browsers used, the pages viewed, the web sites from which a visitor found the Sites, and the search terms and search engines used to find the Sites; and (iii) gather other web analytics information relating to visitors’ use and navigation of the Sites. This information does not identify you personally. On occasion we may aggregate this data with data on the pages visited by other users to track overall visitor traffic patterns and provide this aggregate information to vendors, business partners, or affiliates.
The information we obtain using standard Internet technology, such as web beacons and other similar technologies, enables us to customize the services we offer visitors to our Site, to deliver targeted content, and to measure the overall effectiveness of our online content, advertising, or programming or other activities.
We may use the information you provide in an anonymous or aggregated format that does not identify you personally, which uses might include, without limitation, to evaluate existing products, services, and systems; to assist in the development of new products or services; research; advertising; and to identify trends and changes.
Disclosure of the Data We Collect
In Connection with Our Business. We may disclose your personal information for particular activities, including, without limitation, providing Services to you, payment processing, collections, marketing and research, sharing your stories that you provide to us. In particular, set out below are certain circumstances where we may disclose your personal information without obtaining any further consent:
- Personal information that is supplied to the Sites will be disclosed in accordance with the description of disclosures as set out in the related documentation for the Sites or as may be readily apparent through the general operation of the Sites;
Other Uses and Disclosures
Permitted by Law. Privacy law permits or requires the collection, use and disclosure of personal information without the knowledge or consent of the individual in certain circumstances. We reserve the right to collect, use and disclose your personal information in these circumstances without your knowledge or consent, including: (a) in response to a subpoena, search warrant, court order, or other legal process or request; or (b) to protect and defend our rights or property or those of our related entities, franchisees, or business partners, or others.
Safety and Security. We may collect, use and disclose your personal information as needed to protect the safety and security of our business and assets, including our computer systems, software, personal information and data, and to protect our property and our rights and those of third parties.
Children’s Online Privacy Protection
Our Sites are not directed to children under the age of 13 and we will not knowingly collect personal information from children under the age of 13 on our Sites. If we become aware that we have inadvertently received personal information from a child under the age of 13 on our Sites, we will delete the information from our records.
Security and Accuracy of Personal Information
We take the security of personal information seriously and we take what we believe to be reasonable precautions and have implemented certain safeguards designed to protect the security of data and personal information. We may transmit your personal data to third parties outside Canada for storage or processing. We will attempt to ensure that your personal information will be subject to appropriate safeguards and that it is processed and secured in accordance with applicable law. However, we cannot guarantee against any loss, misuse, unauthorized access or disclosure, or alteration or destruction of data or personal information. While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to or from the Sites, by chat, email or other electronic communications, and you provide such information at your own risk. You acknowledge that: (a) there are security and privacy limitations in computer systems and on the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Sites, chat, email or other electronic communications, cannot be guaranteed; and (c) any such information and data may be viewed or tampered with by a third party while such information or data is being used, transmitted, processed, or stored.
Our Relationship to Other Web Sites
Third Party Organizations
Privacy Rights and Requests
You may have rights under applicable laws concerning personal information we have collected about you, which may include the right to access your personal information we have, to ask us to delete, correct, or restrict the use of your personal information, to withdraw your consent to our use of your personal information, to ask how we have used your personal information, to ask whether we have shared your personal information, and to whom we have shared your personal information. We will honor your rights to the extent required by us under applicable laws or as we may agree to honor in our sole discretion.
All requests relating to your personal information and any concerns you have relating to our privacy practices can be submitted one of the following ways:
99 Émilien-Marcoux, Suite #101
Blainville, Québec J7C 0B4 Canada
Attn: Privacy Requests
All communications must be in the English language. Please clearly state what information you are requesting and any other requests you are making.
We will respond to reasonable requests within the time limits established by applicable law or within a reasonable time if no time limit is established by applicable law.
If you contact us requesting that we take action regarding your personal information or regarding concerns you have relating to our privacy practices, the requesting email MUST come from the email address we have on file for you in order to verify that the request is valid and also to protect your personal information. All other requests must be made in writing or otherwise be verifiable as originating from you. In order to protect your information and because people may have the same name, we will only provide or delete personal information that we can verify is associated with your particular email address or where we can reasonably identify the identity of the requestor.
For your protection, we may ask you for additional information to verify your identity. In most cases, we will provide the information you request and correct or delete any inaccurate personal information you discover. We reserve the right, however, to limit or deny your request to the extent permitted by applicable law, including if: (a) complying with the request may present a threat to the personal safety, property, or rights of any other person or organization; (b) complying with the request may lead to a violation of applicable laws or regulations; (c) we are not required to comply with the request because of a legal rule or exception; or (d) you have failed to provide us with sufficient evidence to verify your identity. We will not delete personal information if that personal information is related to an ongoing transaction. Even after a request, we may also keep personal information where necessary to comply with applicable laws or where necessary to protect a legal right or fulfill a legal obligation or where we are not otherwise required by law to delete the information.
How Long We Keep Personal Information
Subject to applicable law, we retain personal information in accordance with any records retention policy or program we may implement from time to time. We will retain personal information for the length of time necessary to fulfill the purposes for which we collected the personal information or to demonstrate we have fulfilled our duties or obligations, or for retention periods required by applicable law or in which claims may be made or the existence of legal proceedings.
Last updated: January 25, 2021