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Privacy Policy (updated June 1, 2017) This Privacy Policy outlines the privacy practices of Wolseley Canada Inc., its subsidiaries and affiliates ("Wolseley Canada") concerning the collection, use, retention, disclosure and security of personal information obtained with respect to its customers, including credit applicants, applicants for employment and other individuals (sometimes hereinafter referred to as "you" or "your") in Canada in connection with our business and has been developed to comply with Canada's private sector privacy laws, including the Personal Information Protection and Electronic Documents Act ("PIPEDA"), the Personal Information Protection Act (Alberta), the Personal Information Protection Act (British Columbia) and An act respecting the protection of personal information in the private sector (Québec). Protecting individual privacy is important, and Wolseley Canada is committed to maintaining personal information that it obtains secure and confidential. Wolseley Canada generally uses personal information to provide customers with the products and services they have requested, and to get to know you, your needs and your preferences in order to provide you with superior customer service. Personal Information We Collect Accordingly, when used in this Privacy Policy, references to "personal information" include, but are not limited to:
Please note that you are never required to provide us with your social insurance number; however, in order to accurately process a credit application received from you, we require a social insurance number, date of birth or driver's license number. Collection of Personal Information
Use of Personal Information Wolseley Canada may use personal information with the affected individual's consent in connection with credit decision-making, account opening processes and the ongoing administration of our business relationships, including for such purposes as:
In some circumstances, Wolseley Canada may use and disclose personal information without the affected individual's consent, including where:
Disclosure and Transfer of Personal Information We may otherwise disclose personal information as set out below, with the affected individual's consent , or as permitted or required by law.
Personal information disclosed to third parties will be protected by a confidentiality, non-disclosure or other similar agreement requiring appropriate privacy protection. PIPEDA permits Wolseley Canada to disclose personal information to third parties, without the affected individual's knowledge and consent, to:
PIPEDA also permits Wolseley Canada to transfer personal information to a third party without the affected individual's knowledge or consent if the transfer is simply for processing purposes and the third party only uses the information for the purposes for which it was transferred. Wolseley Canada will ensure, by contractual or other means, that third parties to who personal information is disclosed or transferred protects the personal information in accordance with this Privacy Policy and uses it only for the purposes for which it was disclosed or transferred. Your personal information will never be traded, rented or sold to any third party without your consent. Disclosure and Transfers Outside of Canada Accordingly, any personal information which is disclosed, transferred, stored or processed outside of Canada may be subject to legal requirements in foreign countries applicable to Wolseley Canada or the third parties, including the laws of the United States. Consent By signing a credit application and/or other form, implied consent is granted by the individual to obtain and/or to verify information from third parties such as banks, credit bureaus and other lenders in the process of assessing the credit worthiness of an individual or a corporate customer on whose behalf the individual's personal information is collected. An individual can choose not to provide some or all of the personal information at any time, but if Wolseley Canada is unable to collect sufficient information to proceed with the approval of a request for credit, such request may be delayed or turned down. A customer or an individual can withdraw consent to the use of his or her personal information at any time by making such request in writing to Wolseley Canada, at the address noted below in this policy. This Privacy Policy does not cover statistical data from which the identity of individuals cannot be determined. Wolseley Canada retains the right to use and disclose statistical data as it determines appropriate. Retention of Personal Information Personal information will be retained in customer files as long as the file is active and for such periods of time as may be required for reasonable business purposes and as prescribed by applicable laws and regulations. For example, a credit file will be deemed inactive if an application for credit is rejected, when financial obligations are repaid in full or when a guarantee is terminated. Information contained in an inactive file will be retained for a period of seven (7) years, except in the case where an application is rejected; in which case the personal information contained in the file will be retained for a period of up to two (2) years. Accuracy Wolseley Canada endeavours to ensure that any personal information provided by the individual in his or her active file(s) is accurate, current and complete as is necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed. Individuals are requested to notify Wolseley Canada of any change in personal or business information collected by Wolseley Canada. Information contained in inactive files is not updated. Safeguards Wolseley Canada will use physical, organizational, and technological measures to safeguard personal information to only those Wolseley Canada employees or third parties who need to know this information for the purposes set out in this Privacy Policy. This includes limiting access to those employees who need to know such information (for example, those who have to make a determination as to a customer's eligibility for credit); storing files in filing cabinets when not in use and restricting access to work areas where active files may be in use; shredding files prior to disposal to prevent inadvertent disclosure to unauthorized persons; restricting access to Wolseley Canada computers that contain personal information in electronic databases or other formats through password protection and internal Wolseley Canada security policies[D2] , and implementing technical security measures such as limited access data-centers, intrusion detection, firewall technology and secure socket layer certificate authentication. Questions, Requests for Access and Complaints Wolseley Canada Inc. Attn: Chief Privacy Officer Email address: privacy@wolseleyinc.ca 880 Laurentian Drive Burlington, Ontario L7N 3V6 Telephone: (905) 335-7373 Requests for access will be fulfilled within 30 days and individuals will be informed of the existence, use and disclosure of his or her personal information. If upon receiving access, you find that the information held by Wolseley Canada is inaccurate or incomplete, upon providing documentary evidence to verify the correct information, Wolseley Canada will promptly make the required changes to the personal information retained by it; provided, however, that you may be asked to provide identification and/or other proof acceptable to Wolseley Canada to verify such inaccuracies or changes. Recourse Where the Wolseley Canada Chief Privacy Officer makes a determination that the individual's complaint is well founded, the Chief Privacy Officer will take the necessary steps to correct the offending information handling practice and/or revise the privacy policies and procedures of Wolseley Canada. Where the Wolseley Canada Chief Privacy Officer determines that an individual's complaint is not well founded, the individual will be notified in writing of such determination. If the individual is dissatisfied with the finding of and corresponding action taken by the Wolseley Canada Chief Privacy Officer, the individual may bring a complaint to the appropriate Privacy Commissioner for their jurisdiction at the address below: Office of the Privacy Commissioner of Canada www.priv.gc.ca 30 Victoria Street Gatineau, Québec K1A 1H3 Telephone: 1-800-282-1376 Fax: (819) 994-5424 Office of the Information and Privacy Commissioner for Alberta #410, 9925 - 109 Street NW Edmonton, AB T5K 2J8 Phone: (780) 422-6860 Toll-Free: (888) 878-4044 Fax: (780) 422-5682 Office of the Information and Privacy Commissioner for British Columbia www.oipc.bc.ca PO Box 9038 Stn. Prov. Govt. Victoria B.C. V8W 9A4 Phone: (250) 387-5629 Fax: (250) 387-1696 la Commission d’accès à l’information du Québec www.cai.gouv.qc.ca Bureau 2.36 525, boul. René-Lévesque Est Québec (Québec) G1R 5S9 Toll-free: 1 (888) 528-7741 Phone : 418 528-7741 Fax : 418 529-3102 cai.communications@cai.gouv.qc.ca Amendments to Privacy Policy
[D1]Privacy laws require that the information be used for the same purposes, not “similar purposes” [D2]It seems conspicuous that you don’t speak of technological measures guarding against outside intrusion, such as firewalls, intrusion detection, encryption, anti-malware screening, etc. I’ve revised to mention a few common measures, but these should obviously be verified against company practices. |