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.

COPPA'S has prepared this privacy policy ("Privacy Policy") to describe its practices regarding the information collected from its members, the users of its App, and the related online services provided by COPPA'S through the App (the "Services").

If you make any requests regarding access to or removal of your information pursuant to this Privacy Policy, COPPA'S will take reasonable steps to verify your identity, such as requiring your user ID or other personal information associated with your account.

The phrase "Personally Identifiable Information" in this Privacy Policy means personally identifiable information as that term is described in Canadian privacy law and information security law, namely, information about an individual that (either by itself or when combined with information from other available sources) allows that individual to be identified, including, the name, address, telephone number or e-mail address. The phrase "Anonymous Information" in this Privacy Policy means information that does not allow for the identification of an individual or is not associated with or linked to that person's Personally Identifiable Information. Anonymous Information does not enable identification of or contact with individuals.

Please read this Privacy Policy carefully to understand COPPA'S policies and practices regarding your information and how it will collect, use, share, protect or otherwise handle it. If you do not agree with COPPA'S policies and practices, please do not download the App, register for any Services, or otherwise use any Services or the App. By registering for the App and/or using the Services, you agree to this Privacy Policy.

This Privacy Policy may change from time to time, as detailed below.

COPPA'S does not offer an ability to opt-out from the collection of Personally Identifiable Information and Anonymous Information as detailed in this Privacy Policy while still being able to use the App. If you wish to opt-out of the information collection detailed in this Privacy Policy, you must cease using the App and the Services.

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.

ANONYMOUS INFORMATION

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.

Cookies. Like many online services, COPPA'S may use cookies to collect information. The cookies ("Cookies") are small pieces of information that a website sends to your computer's or device's hard drive while you are viewing the website. COPPA'S may use both session Cookies (which expire once you close the web browser) and persistent Cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Services. This type of information is collected to make the Services (and those of third parties) more useful to you and to tailor your experience with COPPA'S to address your special interests and needs. 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 or apps you visit. If you do not accept Cookies, however, you may not be able to use all of the Services or access certain features of the Services. If You have any questions about how to disable or modify Cookies, please let COPPA'S know by contacting it at [email protected].

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.

Collection of Information by Advertisers. COPPA'S may use third parties to serve, place or include advertisements on the Services. Certain third parties may automatically collect information about your visits to the App and other apps and websites, your ISP, your advertising device identifier, and/or the browser you use to visit the Services. They do this by using Cookies or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of the Services and the other sites tracked by these third parties. This Privacy Policy does not apply to, and COPPA'S is not responsible for, Cookies or other technologies in third party advertisements, and COPPA'S encourages you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies. If you would like more information about this, please let COPPA'S know by contacting it at [email protected].

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.

AFFILIATES. COPPA'S may also share some or all of your Personally Identifiable Information with its subsidiaries, joint ventures, or other companies under a common control ("Affiliates") and will require its Affiliates to honor this Privacy Policy.

BUSINESS TRANSACTIONS. COPPA'S may share some or all of your Personally Identifiable Information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of its business or assets. In the event of an insolvency, bankruptcy, or receivership, Personally Identifiable Information may also be transferred as a business asset. If another company acquires the COPPA'S company, business, or assets, that company will possess the Personally Identifiable Information collected by COPPA'S and will assume the rights and obligations regarding your Personally Identifiable Information as described in this Privacy Policy.

OTHER DISCLOSURES. Regardless of any choices you make regarding your Personally Identifiable Information (as described below), COPPA'S may disclose Personally Identifiable Information if it believes in good faith that such disclosure is necessary: (i) in connection with any legal investigation; (ii) to comply with relevant laws or government requests or to respond to subpoenas or warrants served on COPPA'S; (iii) to protect or defend COPPA'S rights or property or other users of the Services; or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or COPPA'S Terms and Conditions of Use, including as part of credit fraud protection. COPPA'S may also use and disclose your Personally Identifiable Information as required or authorized by applicable laws.

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.

ANONYMOUS INFORMATION

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.

E-MAIL COMMUNICATIONS. COPPA'S may periodically send you free electronic newsletters and e-mails that directly promote the use of the App or the Services. When you receive newsletters or promotional communications from COPPA'S, you may indicate a preference to stop receiving such further communications from COPPA'S and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting COPPA'S directly at [email protected]. Despite your indicated e-mail preferences, COPPA'S may send you service related communications, including notices of any updates to the Terms and Conditions of Use or Privacy Policy, from which you may not opt out.

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 advertisers and partners. For example, COPPA'S may use or provide Anonymous Information to create consumer profiles and segments for targeted advertising. Because COPPA'S shares only Anonymous Information with advertisers, advertisers are unable to identify you through this information. Also, the Anonymous Information COPPA'S shares with advertisers will be aggregated, subject to the rest of this Privacy Policy.

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.

COPPA'S may also share Anonymous Information with third party service providers ("Analytics Companies") to help analyze how users use the Services. These Analytics Companies may also use Cookies and/or other technologies to collect information such as how often users visit the App and how they use the Services. COPPA'S does not combine the information gathered by Analytics Companies with your Personally Identifiable Information, and the collection of this information does not enable these Analytics Companies to identify or contact you.

COPPA'S may also share Anonymous Information with third party service providers ("Third Party Companies") to help with the functional features of the App for provision of the Services. These Third Party Companies may also use Cookies and/or other technologies to collect information such as purchase information, payment information, visits to the App and how members use the Services. COPPA'S does not combine the information gathered by the Third Party Companies directly with your Personally Identifiable Information, and the collection of this information directly from COPPA'S does not enable these Third Party Companies to contact you.

5. TREATMENT OF INFORMATION DISCLOSED TO THIRD-PARTIES.

This Privacy Policy addresses only COPPA'S use and disclosure of information it collects from and/or about you through its Services. If you disclose information to others, or authorize COPPA'S to do the same under this Privacy Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. COPPA'S does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

The Services and the App may contain content or links to other websites that are not owned or controlled by COPPA'S. COPPA'S has no control over, does not review, and is not responsible for the privacy policies of or content displayed on such other sites. When you click on such a link, you will leave the Services and go to another site. During this process, another entity may collect Personally Identifiable Information or Anonymous Information from you. The Services may also contain links to websites that are controlled by COPPA'S but operate under different privacy policies. Please review the privacy policy of any new site you visit.

6. CHANGES TO THIS PRIVACY POLICY.

This Privacy Policy may be updated in the future, from time to time, for any reason. COPPA'S will notify you of any changes to its Privacy Policy by posting the new Privacy Policy on the App and changing the "Last Updated" date. COPPA'S may take such other actions as it deems appropriate under the circumstances to announce such changes. You should consult this Privacy Policy regularly for any changes. If COPPA'S decides to use Personally Identifiable Information in a manner different from that stated at the time that it was collected, COPPA'S will notify affected individuals by e-mail. Individuals can choose whether or not to allow COPPA'S to use Personally Identifiable Information related to them in this new manner.

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.