E.S. GALLAGHER SALES LTD.
CUSTOMER PRIVACY STATEMENT
February 1st, 2006
This Privacy Statement explains our privacy practices for our customers who register to use our Web site, www.esgallagher.com. In this Privacy Statement, the terms "ESG", "we" and "our" refer to E.S. Gallagher Sales Ltd., unless otherwise indicated. Personal information collected or provided when customers visit other non-Canadian websites which are operated by our affiliates, are governed by the privacy statement that is posted on that website.
1. ESG's Commitment to Privacy.
At ESG, we are committed to protecting the privacy of our customers. For that reason we have taken, and will continue to take, measures that protect the privacy of personal information held by us.
This Privacy Statement provides you with details regarding: (1) why we collect personal information; (2) what we do with that information; (3) the steps we take to ensure that access to that information is secure; (4) how you can access personal information pertaining to you; and (5) who you should contact if you have questions or concerns about our policies or practices.
Since we regularly review our policies and practices, your comments are always welcome. We reserve the right to change this Privacy Statement at any time; however, any changes or additions to Section 4 regarding the reasons we use personal information will not apply to you unless you consent to them. We will alert you that changes have been made by indicating at the top of the Privacy Statement the date that it was last updated. This Privacy Statement was last updated on January 1st, 2006. There have been no other updates since this Privacy Statement came into effect on January 1st, 2006. We encourage you to review our Privacy Statement to make sure that you understand how information that you provide will be used.
2. What is personal information?
Personal information means information that would allow a specific individual to be identified or information that can be directly associated with an individual. For example, this includes your name, postal or e-mail address, telephone number, and demographic information. Personal information does not include aggregate information (data about a group or category of products, services or customers, from which individual customer identities have been removed). For example, information about how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data. Likewise, information about the products you purchase may be collected and combined with information about the products purchased by others. Aggregate information about product purchases helps us understand trends and customer needs, and assists us in product selection, product ordering and sizing and the introduction of new products and services. It can also assist us in new Web site functions by looking at Web site browsing activities.
3. When we collect personal information.
4. How we use personal information.
As part of our business operations, we hold and use certain personal information pertaining to you in order to process your requests, if you ask us to, to tell you about opportunities we think will be of interest to you, such as our promotional programs and to understand your needs so that we can serve you better. Specifically, we may use personal information for the following purposes:
5. When we share personal information.
From time to time we engage unaffiliated third parties to perform certain services. The companies that are provided with the personal information are first required to sign an agreement that obligates them to keep the information confidential and secure and prohibits them from using it for unauthorized purposes.
Third party suppliers can only use the personal information that we share with them to provide that they have your consent, to notify you of their offerings and to evaluate new and existing products, offerings or services. We are not responsible for any additional information you provide directly to these third parties, and we encourage you to become familiar with their privacy and security practices and policies before disclosing information to them. There may be instances when we provide information relating to our business customers to various suppliers so they can conduct market studies and other promotional activities.
We will also disclose personal information in accordance with Section 10 below when the information is collected on-line at esgallagher.com, or if a law, regulation, search warrant, subpoena or court order legally authorizes us or requires us to do so or to protect the rights, property or personal safety of E.S. Gallagher Sales, its customers, employees or other members of the public.
Except as set out above, we do not sell, rent, share or disclose the personal information to others for a fee without your consent.
6. How long do we hold personal information?
Personal information is retained only for so long as is necessary for the purposes set out above. When no longer required, we will destroy, erase or de-personalize the personal information. Legal requirements may necessitate our retaining some or all of the personal information we hold for a period of time that is longer than we might otherwise hold it.
To ensure that the personal information you provided is accurate, complete and up-to-date, we urge you to provide us with updates regarding such information and to inform us of any errors affecting the personal information we hold. You may update, review or correct your esgallagher.com on-line account information at any time by accessing your password-protected registration page via the "My Account" area of the Web site.
8. Security measures.
We will continue to keep in place security measures in an effort to protect personal information held by us from unauthorized use, access, disclosure, distribution, loss or alteration. We employ physical, administrative, contractual and technological safeguards to appropriately protect personal information. Access to personal information will be restricted to our authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties. Please also see our "On-line privacy practices" in Section 10 below.
We periodically update our policies regarding information security measures in an effort to protect the personal information held by us in the most effective manner possible.
9. Accessing personal information.
Our customers are entitled to access the personal information held by us concerning them. In recognition of the importance we attach to each customer's personal information, you can only access personal information we hold about you. You can access the personal information you provided to us by showing documentation to confirm your identity and completing a written request for such information on a form we provide. We will generally respond to your request for information within thirty (30) days, unless, for reasons beyond our control, a longer response time is necessary, in which case you will be advised accordingly. While our response will generally be provided at no cost, you will be informed in advance of any charges that apply in connection with the information request. Charges may relate to the transcription, reproduction or transmission of personal information held by us. Personal information may be stored by ESG at our Canadian head office in Toronto, Ontario.
In very limited circumstances, we may not be able to supply personal information for reasons of a legal nature, including privileged communications between professional and client or a pending judicial proceeding. In each case, we will provide written reasons outlining why your request for access has not been granted by us.
10. On-line privacy practices.
Use: We use personal information collected on-line as described in Section 3 above. In addition, we use personal information: (a) to facilitate and monitor certain features of our Web site that you choose to interact with, such as on-line forums and chat rooms if available; (b) to respond to your questions and concerns and to understand your needs and preferences; (c) to conduct surveys and other research; (d) to provide you with customized Web site content and advertising; and (e) to fulfill your on-line orders for products and services. For example, we may share on-line personal information with our warehouses to facilitate product deliveries, pickups or returns.
Sharing: We share personal information collected on-line as described in Sections 5 above. In addition, we may provide third parties with certain information that is necessary to fulfill an order you have placed with us. For example, if you request shipment for a purchase, we may provide your address to the shipping carrier and customs service providers, we also may use third parties to host and administer the Web site, process and store data, and fulfill other technology-related functions on our behalf. However, we only give or permit access to vendors, suppliers and others involved in Web site administration and the commerce distribution chain the limited information needed to perform their duties and provide you with the products and services you order. We are not responsible for any additional information you provide directly to these parties.
Protection: Personal information we collect on our Web site is stored electronically, and may be combined with other off-line information. Personal information entered on our Web site is encrypted using a security protocol called SSL (Secure Sockets Layer). SSL encrypts information entered on our site before it is sent over the Internet. SSL also allows you to view securely your on-line account and registration information. Account information is accessible on-line only through the use of a password. To protect the confidentiality of personal, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Web site by any person using your password. You are advised that, unlike communication within our Web site, we have no control over the privacy of your e-mail communications with us while in transit. We recommend that you do not include confidential, proprietary, personal information in e-mails, including passwords and other similar information. Also, if other people have access to your e-mail account, they may be able to access your password and obtain personal information about you, or change information about your user profile. Please advise us immediately by e-mail at firstname.lastname@example.org by dialing 1.800.430.6754 if you believe your password has been misused.
Children: We encourage parents to take an active interest in their children's use of the Internet. We do not intend to collect information from children who are under 18 years of age. If you are under 18, please do not provide information on our Web site, and ask your parent or guardian to do so for you.
11. Complaint process.
If you are not completely satisfied with or wish to submit comments concerning this Privacy Statement or its application by us, we invite you to convey your concerns or suggestions to E.S. Gallagher Sales Ltd, 920 Caledonia Road, Unit 3B, Toronto, ON, M6B 3Y1, Canada; Attention: Marketing/Communications Director. We will reply as quickly as possible and inform you of the steps, if any, that has been or will be taken in order to address the concern or implement the suggestion.
If you (1) previously consented to receive promotional information from ESG about our products, offerings or Customer Services, (2) previously consented to the sharing of the personal information you provided, or (3) are a Business Member and you do not want us to disclose information about your purchases, you can change your mind by:
1. Calling our Customer Service representatives at 1.800.430.6754;
3. E-mailing us at email@example.com
4. Writing us at: E.S. Gallagher Sales Ltd, 920 Caledonia Road, Unit 3B, Toronto, ON, M6B 3Y1, Canada