Updated on June 25, 2024
GCO Canada ULC. (“GCO”) values its customers and respects their privacy. This Privacy Policy (“Policy”) describes the personal information we may collect from you, the purposes for which we collect it, how we process it and when we may share it with third parties. This Policy also describes the choices you can make about how we collect, use and disclose your information.
This Policy applies to your use of the www.littleburgundyshoes.com website (“Website”) regardless of whether you access or use it via a computer, mobile device or another platform. This Policy also applies to personal information we obtain through email communications, our online channels (including other websites, online product catalogs, mobile applications and social media websites that reference this Policy) and to personal information you provide us offline (e.g., at one of our retail stores) (all such online channels, website, online product catalogs, mobile applications, social media sites, and offline interactions shall collectively be referred to herein as the “Services”).
The terms "you," "your" and "yours" refer to the person whose personal information is collected or processed by GCO. The terms "we," "us" and "our" refer to GCO.
The Policy is organized under the following topics:
1 – What categories of personal information do we collect?
2 – How do we collect your personal information?
3 – Why do we collect and use your personal information?
4 – To whom do we disclose your personal information?
5 – How do we protect your personal information?
6 – How long will we keep your personal information?
7 – Children under the age of 14
8 – Your rights in relation to your personal information
10 - Hyperlinks to other websites
1 – What categories of personal information do we collect?
Privacy laws in Canada generally define "personal information" as any information about an identifiable individual. This includes information that can be used alone or with other information to identify, contact or locate a particular person. Information from which all direct and indirect identifiers have been removed is not personal information.
We may collect, use, store and transfer the following categories of personal information:
(a) contact details, such as personal and business email address, shipping address, postal code and telephone number(s);
(b) financial information, including the payment information used to make a purchase on our Website (e.g., partial credit card number or tokenized credit card information) and information about your rewards on LB Club;
(c) career profile information, such as your online recruitment password, how you heard about us, the information of the person who referred you for a position at GCO, your status as an employee of GCO, the legal status that allows you to work in Canada, and any other information you choose to add to your career profile at https://www.littleburgundyshoes.com/careers-pages/apply-now (our “Careers” Website);
(d) identity information, such as first name, last name, username, gender, date of birth (month, day, year), and title;
(e) technical information, such as Internet Protocol (IP) address and geolocation information, cookies, browsing history, search history, information about how you interact with our Website, and other technologies on the devices you use to access the Website;
(f) purchase history, including a description of the items purchased online or offline, the date of the purchase, amount paid. The purchase history includes your history of returns made after a purchase; and
(g) security footage, such as CCTV footage captured at one of our retail stores.
Not all information we collect identifies you or can be attributed as being identifiably about you when taken on its own. Similarly, we may aggregate your information with other information in a way that it is not attributable as being identifiably about you (including by aggregating it into groups or categories). This Policy does not apply to restrict our collection, use or disclosure of such non-identifiable information. However, this same information may be considered personal information if we combine it with other information (such as identifiers like your name or address) in a way that makes it attributable as being identifiably about you. This Policy will apply to your information when it is combined in this identifiable way.
If you provide GCO with another person's personal information, you represent that you have obtained all necessary consents from that person to authorize us to collect, use and disclose that personal information for the purposes set out in the Policy.
2 – How do we collect your personal information?
We use a variety of methods to collect your personal information, including the following:
a) Direct interactions. In interacting with us, you may provide us with your personal information, such as when you do one of the following:
i. sign up for our newsletter;
ii. make a purchase online or in a retail store;
iii. participate in a promotion or survey;
iv. create a user account and choose a password on the Website;
v. join the LB Club;
vi. contact us directly with comments or questions via a contact form available on our Website; or
vii. apply for a job opportunity on our Careers Website.
b) Indirect interactions. We collect certain personal information about you indirectly from our service providers with whom you also do business. This occurs when we receive your application for a vacancy through a recruitment agency, or when we obtain your contact and identity information from a third party for marketing purposes. We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers and employees, and provide products and services that may be of interest to you.
Any indirect collection of your information is done in accordance with this Policy, any privacy policies of the service provider in question, and in accordance with applicable laws.
c) Automated technologies or interactions. When you interact with our Website, we will automatically collect technical information regarding the computer equipment used to navigate our Website and your browsing trends. We collect this information using cookies, pixels, server logs and other similar technologies. We may also receive your technical information if you visit third-party websites that use our cookies.
3 – Why do we collect and use your personal information?
We may use your personal information for the purposes for which it was collected, in accordance with our Policy, for other purposes authorized by law or with your consent.
We may use the information collected for the following purposes:
|
Purpose |
Type of personal information |
|
To enable you to make a purchase, return a purchase, or exchange an item |
· Contact details · Financial information · Identity information |
|
To support our marketing/advertising efforts |
· Contact details · Identity information · Technical information · Purchase history |
|
To register on our Website or the LB Club |
· Contact details · Identity information |
|
To respond to your requests, and to communicate information with you at your request |
· Contact details · Identity information · Other information required to address your request |
|
To improve the performance of level of service and the content of our Website |
· Contact details · Identity information · Technical Information · Purchase history |
|
Provide access to our Careers Website and administer employment opportunities. |
· Contact details · Identity information · Career profile information |
|
To prevent or detect crime, protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting) |
· Contact details · Identity information · Financial information · Technical information · Purchase history · Security footage |
|
Comply with obligations imposed by applicable law. |
· As applicable. |
As stated below in section 8 (e), you may always choose not to receive promotional material or commercial information from GCO. For increased safety, we will not send you commercial emails without your express consent.
4 – To whom do we disclose your personal information?
Except as set out below, GCO does not disclose or sell the personal information you have provided us to third parties.
GCO discloses your personal information to third parties in the following circumstances:
· to our service providers who help us achieve the purposes for which your personal information was collected, including server hosting providers who help us store your personal information;
· to a third party (e.g., co-branding partners or GCO affiliates) where you express interest in, or choose to purchase or participate in, a promotion, program, activity, service, or product offered by the third party. However, if you do not want your personal information to be shared in this way, you may opt not to express interest in, or not to purchase or participate in, such promotions, programs, activities, services, or products;
· to comply with our obligations under any law or regulation, investigation by a government authority, subpoena or court order, or other administrative or governmental authority;
· to a law enforcement agency or government agency in connection with an investigation of fraud, real or potential, a violation of a law, regulation or conditions of use of the Website, or for the protection of rights, ownership or security of GCO, our customers/users or partners;
· to an acquiring entity in connection with the completion or proposal of a business transaction (including its achievement/implementation, liquidation, foreclosure or repossession), concession, merger, business combination or any other type of acquisition, liquidation, transfer, transfer contract or financing of GCO, in whole or in part, or of any property, stock, asset, share or business of GCO; and
· If you choose to share personal information publicly, with other users of the Website, or with other sites (such as social media sites), we may facilitate this sharing. We do not control these third parties that you might choose to share your personal information with or how they use your personal information, and we are not responsible for their privacy practices. You should review the privacy policies of any third party before you decide to share your personal information with them and always exercise caution when publicly sharing your personal information.
We require service providers to safeguard the security of your personal information and to treat it in accordance with the law. We do not allow our service providers to use your personal information for their own purposes and we only allow them to process your personal information for specific purposes and in accordance with our guidelines.
By providing us with personal information, you acknowledge and agree that such personal information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada and in the United States, where laws regarding the protection of personal information may be less stringent than the laws in your jurisdiction. Further, such personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information.
5 – How do we protect your personal information?
GCO has implemented physical, technological, contractual and administrative measures to protect your personal information from accidental loss and unauthorized access, use, modification and disclosure.
To prevent unauthorized access to your user profile on our Website, please maintain the accuracy and integrity of the personal information associated with your user profile and ensure that this information is used appropriately.
While efforts are made by GCO to ensure that unauthorized third parties will not access or obtain your personal information through the Website, complete confidentiality and security are not currently guaranteed on the Internet. Communication via the Internet may be intercepted, lost or altered. You acknowledge and agree that GCO will not be liable for damages resulting from the transmission of confidential information or personal information via the Internet and that such communications are made at your own risk and peril.
6 – How long will we keep your personal information?
We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in our Privacy Policies, including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.
When the personal information collected is no longer required by us, the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form are applied as permitted or required under applicable laws.
7 – Children under the age of 14
The Website is not intended for children under the age of 14. No one under age 14 may provide personal information on the Website. We do not knowingly collect personal information from children under age 14. If you are under 14, do not use or provide any information on any Website or through any of its features, do not make any purchases on our Website or provide us with any information about you, including your name, address, telephone number or email address. If we learn we have collected or received personal information from a child under the age of 14 without verified parental consent, we will delete that information.
8 – Your rights in relation to your personal information
Subject to certain exceptions as permitted by law, you have the following rights with respect to the personal information we hold about you:
a) Your right to access
You have the right to access the personal information we hold about you and to receive a general account of our use of that personal information. Upon receipt of a written request from you, we will provide you with a copy of your personal information, although under certain limited circumstances, we may not be able to make all relevant personal information available to you, such as when the personal information also affects another natural person. In such circumstances, we will inform you, upon request, of the reasons for this refusal. We will endeavour to process all requests for access to personal information in a timely manner.
b) Your right to correct
If the personal information we hold about you is inaccurate or incomplete, you have the right to have it corrected. If appropriate, this corrected personal information will be provided to the parties to whom we are authorized to disclose your personal information. We will endeavour to process all requests for correction of personal information in a timely manner.
c) Your right to delete
You may ask us to delete or remove your personal information in certain circumstances, such as when we no longer need your information for the purposes for which it was collected, or if you withdraw your consent (where applicable, as your consent is the legal basis for our processing of your personal information). If you have the right to delete your personal information and if we have disclosed it to third parties, we will take reasonable steps to inform them to the extent possible and in cases where this would not require a disproportionate effort. If you so request, where possible and lawful, we will also inform you of the identity of the third parties with whom we have shared your personal information so that you can contact them directly.
d) Your right to the portability of personal information
You may have the right, in certain circumstances, to obtain the personal information you have provided to us (in a structured, commonly used and computer-readable format) and to re-use it elsewhere, or to ask us to transfer it to a third party of your choice.
e) Your right to withdraw consent
If we rely on your implied or expressed consent as the legal basis for processing your personal information, you have the right to withdraw it at any time. However, this withdrawal will not affect the legality of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will inform you if this is the case when you withdraw your consent.
To exercise any of the rights listed above, please use this Request Form
We may use cookies to track your preferences and activities on the Website. These cookies on the Website may be generated, analyzed and managed by Google Analytics, Google Search Console, Google Tag Manager, and Facebook Pixels. By using and visiting any Website, you consent to our use of cookies on and off that Website.
Cookies are small data files that are transmitted to your computer's hard drive by our Website. They record your preferences so that your subsequent visits to this Website run more efficiently. Cookies can store a range of information, including the number of times you visit our Website, your sign-in information, and the number of times you visit a page or other element of the Website. We use cookies on the Website to:
i. improve online customer service and functionality of the Website;
ii. customize the content of the Website;
iii. tailor and measure advertising; and
iv. provide a safer experience.
Most browsers are designed to accept cookies, but they can easily be modified to block them. Your browser's help files contain information about blocking cookies, detecting cookies that are sent to you and disabling them.
· You can also choose the opt-out option by clicking on: http://optout.networkadvertising.org/?c=1 or https://optout.aboutads.info/?c=3&lang=fr.
· You can also prevent analytics information from being transferred to and processed by Google Analytics, by downloading and installing the Google Analytics Opt-out Browser Add-on available at: https://tools.google.com/dlpage/gaoptout?hl=en.
10 - Hyperlinks to other websites
The Website may contain hyperlinks enabling users to visit sites maintained by other entities. GCO has no control over these websites and is not responsible for those listed on its Website. Any information you transmit to these websites will be subject to privacy policies applicable to these websites.
Icons leading directly to social media accounts (collectively "Social Media") (such as Facebook, Twitter, Instagram and YouTube) will be available on the Website's home pages. Social Media accounts are managed by GCO's internal communications team. GCO will make every reasonable effort to respond to any comments or questions on Social Media within a reasonable time.
We reserve the right to make changes to this Policy at any time. If GCO makes any changes to the Policy, such changes will be posted on the Website and will be effective immediately thereafter.
Your continued use of the Website after any changes constitutes your acceptance of the updated Policy. You agree to regularly review this Policy to be aware of any changes.
If you have any questions regarding our privacy practices, this Policy, or if you wish to exercise any of your rights with respect to your personal information, please contact GCO's Privacy Officer at:
GCO
Attention: Privacy Officer
535 Marriott Drive, Nashville, TN 37214
Email: [email protected]
