The COPPA'S World of Rewards Program (the .Program.) is a rewards program offered by 2360083 Ontario Limited and its subsidiaries and related entities (.COPPA'S") under certain terms and conditions to the members of the Program though its mobile application (the "App"). This program is available through participating grocery store locations and websites operated by COPPA'S.
1. TYPES OF INFORMATION COPPA'S COLLECTS ABOUT YOU AND HOW IT IS COLLECTED.
In general, there are two types of information COPPA'S collect about you . Personally Identifiable Information and Anonymous Information, as defined above.
PERSONALLY IDENTIFIABLE INFORMATION
In general, the Personally Identifiable Information collected enables COPPA'S to provide its Services and use of the App and make COPPA'S Services more relevant and useful to you. When you download the App, COPPA'S will collect your e-mail address as provided. COPPA'S also collects Personally Identifiable Information that you submit voluntarily, for example, at registration, when you sign up for the App, through e-mail or text notifications, through your claiming or using special offers, in the course of your use of the Services and the App, when you respond to surveys, and when you otherwise communicate directly with COPPA'S. To use certain features of the Services, COPPA'S requires you to create an "Account" by providing your name, phone number, address, e-mail and/or a password. When you use the Services, COPPA'S will collect all information necessary to process the transaction. Through your use of the Services, COPPA'S may also collect additional information, including your IP address. In addition, the Services may access your device's image storage applications and contacts, with your consent, to facilitate your use of certain features of the Services.
When you communicate with COPPA'S or otherwise interact with publicly available areas of the Services and the App, including posting comments, ratings, or reviews, COPPA'S will collect and store any information that is contained in your communications and/or comments. Any information you choose to provide when using the Services should reflect how much you want COPPA'S to know about you. You can choose not to provide COPPA'S with certain information, but this may limit the features of the Services and the App.
As you use the App, COPPA'S may collect location-based information from you through your mobile or other location-aware device. Certain of COPPA's Services may be location-specific and can provide helpful information based on where you are. If you consent to telling COPPA'S where you are (i.e., by allowing your mobile device to send COPPA'S your location), COPPA'S may use that information to provide you with location-based information. If you want to deactivate this feature, you can disable location services on your mobile device, but COPPA'S will not be able to provide those Services.
When your Personally Identifiable Information is collected, COPPA'S may automatically associate that information and information as collected with your Account so that COPPA'S can identify you across multiple devices, browsers and networks. COPPA'S may also obtain information about you from a third-party data aggregator, cookie technology operator, advertising network, or other form of data company.
Please remember that others may have access to your device. To protect your privacy, you should always log out from the App after using it.
Consent. COPPA'S will only collect, use and disclose your Personally Identifiable Information with your knowledge and consent, except where permitted or as required by law. COPPA'S will not rent, sell, or otherwise distribute your Personally Identifiable Information without your permission. Your consent to use your Personally Identifiable Information is implied for the following purposes:
- Fulfilling your Service requests.
- Updating you as to the tally of your ongoing savings from use of the App.
- Alerting you to important Service revisions or updates.
- Ensuring that you are properly registered to receive technical support for certain Services.
Accuracy. COPPA'S will keep your Personally Identifiable Information as accurate, complete and up-to-date as necessary for the identified purposes for which it was collected. COPPA'S encourages you to let COPPA'S know if your contact information changes.
Limits on Collection of Personally Identifiable Information: COPPA'S will not collect Personally Identifiable Information indiscriminately, but will limit its collection of Personally Identifiable Information to that which is reasonable and necessary to perform the Services. COPPA'S will also collect Personally Identifiable Information as authorized by law.
COPPA'S collects the following types of Anonymous Information:
Information Collected by its Servers. To make the Services more useful to you, COPPA'S servers (which may be hosted by a third party service provider) may collect certain anonymous information from you, including your mobile device details, browser type, operating system, domain name and/or a date/time stamp for your visit.
Log Files. As is true of most apps and websites, COPPA'S gathers certain information automatically and stores it in log files. This information may include your mobile device details, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. COPPA'S uses this information to analyze trends, administer the Services, track users' use of the Services, gather demographic information about its user base as a whole, and better tailor its Services to its users' needs. For example, some of the information may be collected so that when you visit the Services again, it will recognize you and the information could then be used to serve advertisements and other information tailored to your interests.
Mobile Devices. COPPA'S may collect information about the computer or device you use to access the Services, including the hardware model, operating system and version, and any address. For more information about how you can control COPPA'S access to these applications, please see "Your Choices" below.
2. HOW COPPA'S USES AND SHARES THE INFORMATION IT COLLECTS.
PERSONALLY IDENTIFIABLE INFORMATION
COPPA'S may use your Personally Identifiable Information to:
- Create and administer your Account;
- Process and fulfill your transactions;
- Provide you with the Services and customer support;
- Personalize and tailor the features and content of the Services to you;
- Provide the loyalty services and Rewards, including the management of the Program accounts to accurately record and update the Program Rewards;
- Communicate information and arrange offers to members and other parties, including but not limited in respect of the Program Rewards;
- Understand and analyze the responses, needs and preferences of members and to develop, enhance, market and/or provide products and services to meet those responses, needs and preferences;
- Enable members to participate in surveys and contests;
- Market COPPA'S products, offers and services, and those of third parties, to you that COPPA'S believes may be of interest to you, including through text message or SMS, push notifications, and special offers in the App;
- Send newsletters, offers, updates, notices, announcements and additional information to you related to the Services and those of third parties;
- Understand how the Services are used so COPPA'S can continue to improve the Services provided to you;
- Create consumer profiles and audience segments which may be used for targeted advertising of the Services;
- Find and connect with you to provide special offers from COPPA'S or third parties;
- Permit the use of the Pre-paid card feature of the App;
- Respond to your requests, resolve disputes and/or troubleshoot problems;
- Deter fraud or other potentially illegal activities or to otherwise protect COPPA'S, you and others from error and to safeguard COPPA'S business interests;
- Comply with legal and regulatory requirements;
- Verify your compliance with your obligations in COPPA'S Terms and Conditions of Use and otherwise enforce those Terms and Conditions of Use; and
- Communicate with you about the Services.
COPPA'S may also use your Personally Identifiable Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.
Protecting the privacy and confidentiality of your personal information has always been a fundamental principle in COPPA'S relationship with you. This Privacy Statement tells you how COPPA'S will ensure the confidentiality and privacy of the information that you entrust to COPPA'S.
COPPA'S will only use or disclose your Personally Identifiable Information for the purposes set forth herein and as authorized by law. When your Personally Identifiable Information is to be used for a purpose not previously identified, COPPA'S will disclose that new purpose to you before such use. COPPA'S will keep Personally Identifiable Information used to make a decision affecting you for at least one year after using it to make such decision. COPPA'S will otherwise destroy, erase or make anonymous all records containing Personally Identifiable Information when it is reasonable to assume that the original purpose is no longer being served by retaining the information and retention is no longer necessary for a legal or business purpose.
COPPA'S may share Anonymous Information in the ways described above; however, with the exception of those examples above, the information COPPA'S otherwise shares with third-parties is limited to Anonymous Information. COPPA'S uses the Anonymous Information it collects to analyze trends, administer and improve the Services, track users' movements in the App, and better tailor its Services (and those of any third parties) to its users' and potential users' needs. For example, some of the Log Files may be collected so that when you use the App again, it will recognize you and the information could then be used to make available information tailored to your interests. COPPA'S reserves the right to disclose Anonymous Information publicly without restriction.
3. HOW COPPA'S PROTECTS YOUR INFORMATION.
COPPA'S takes the security and privacy of your information seriously. COPPA'S use reasonable security arrangements to protect the Personally Identifiable Information in its custody or control against unauthorized access, collection, use, alteration, disclosure, copying, modification, disposal or similar risks. COPPA'S will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of Personally Identifiable Information protection is implements by its suppliers, vendors and agents.
Unfortunately, while COPPA'S makes reasonable efforts to ensure that your information is secure on its system, no data transmission over the Internet can be guaranteed to be 100 percent secure. As a result, COPPA'S cannot guarantee the security of any Personally Identifiable Information you transmit to COPPA'S, and you do so at your own risk. Your use of the Services and the App demonstrates your assumption of this risk.
4. YOUR CHOICES REGARDING YOUR INFORMATION.
COOKIES. If you decide at any time that you no longer wish to accept Cookies from the Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser's technical information. If you do not accept Cookies, however, you may not be able to use all of the Services or certain features of the Services. If you have any questions about how to disable or modify Cookies, please let COPPA'S know by contacting [email protected].
LOCATION INFORMATION. You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of any location information, you may not be able to use all of the Services or certain features of the Services.
CHANGING OR DELETING YOUR PERSONALLY IDENTIFIABLE INFORMATION. You may access, review, update, correct, or delete the Personally Identifiable Information in your Account by contacting COPPA'S. Certain information is necessary in order for COPPA'S to provide the Services. Therefore, if you choose to delete such necessary information you may not be able to use the Services. If you choose to delete all of your Personally Identifiable Information, then your account may become deactivated. Please remember, however, if COPPA'S has already disclosed some of your Personally Identifiable Information to third parties, COPPA'S cannot access that Personally Identifiable Information any longer and cannot force the deletion or modification of any such information by the parties to whom COPPA'S has made those disclosures. In addition, publicly available information will not be deleted from the Services, nor will any information COPPA'S is legally obligated to retain.
CLOSING AN ACCOUNT. Upon your request, COPPA'S will close your Account. Please note that COPPA'S will delete your Personally Identifiable Information except as necessary to comply with laws, prevent fraud, resolve disputes, assist with any investigations, enforce its Terms and Conditions of Use or for legitimate business purposes to the extent permitted by law. Once your Account is deactivated, you will no longer have any access to any features of the App, any information in the App, any Rewards or any Services available through the App.
COPPA'S may also share Anonymous Information with third party tracking or other such services ("Tracking Services") to help COPPA'S analyze how users use the Services. These Tracking Services collect only the advertising device identifier assigned to your mobile device, rather than your name or other personally identifiable information, and use it to collect information such as how often users open the App and what features they use in the App. COPPA'S will only use this information to improve its Services and to better tailor its offerings and Services to you. COPPA'S does not combine the information generated thereby with your Personally Identifiable Information. The collection of this information does not enable these Tracking Services to personally identify or contact you.
5. TREATMENT OF INFORMATION DISCLOSED TO THIRD-PARTIES.
COPPA'S respects the privacy of members and if you have any issue about privacy, simply inform COPPA'S at [email protected]
Effective Date December 6, 2018.