TWA Law (the “Company,” “we,” “us,” “our”) is committed to protecting the privacy of its customers and the confidentiality of their Personal Information. This Policy describes key principles and practices followed by the Company with respect to its collection, use, or disclosure of Personal Information in the course of carrying out its business and activities related thereto.
“Personal Information” means recorded information about an identifiable individual. To qualify as Personal Information, the information must be about the individual in a personal capacity. Examples of information that could be Personal Information include your name, address, gender, date of birth, language preference, email address, telephone number, credit card information, personal opinions, Twitter user name or other social media user identification.
- Collection of Personal Information
The Company may collect Personal Information from customers in person, over the telephone, by mail, by fax, or through online services. The Company uses Personal Information about you and your use of its website, https://twalaw.ca (the “Website”), for various purposes, including but not limited to the following:
- to process, verify, and deliver your orders;
- to better understand your product preferences;
- to track and analyze trends and patterns;
- to conduct and administer surveys and contests;
- to comply with legal and regulatory requirements;
- to create aggregated information that does not allow you to be personally identified or contacted; and
- to send communications, including promotional campaigns, informing you about products and services.
The most common situations where the Company may collect and use your Personal Information are set out below.
- Visiting the Website
When you visit our Website, we may collect information that is automatically sent to us by your web browser. This information may include your domain name and your numerical IP address. We may also collect other information, such as the type of browser you use, which pages you view, and the files you request. We use this information to better understand how visitors use our Website and to improve our Website to better meet your needs. The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit or how you may change or restrict this.
- Product Purchases and Deliveries
Product Purchase. You may be required to provide Personal Information when you order products from the Company’s Website. Personal Information is required in order to process these transactions, to verify your identity, age and to protect against error or fraud. If you use a credit or debit card for your purchase, your credit/debit card-related information and your signature are required to process your payment.
Product Delivery. At delivery, you may be asked to present valid government photo identification to confirm that you are of legal age. If picking up from a delivery depot, you will also be asked to verify that you are someone who is authorized to pick up the package. When requested, identification is viewed, but not recorded. In all cases, the name and signature of the person accepting the package will be recorded as confirmation that the delivery has been received.
- Email and Other Communications
From time to time, the Company may obtain your consent to send you emails and other communications about products, services, promotions, events or administrative functions. The Company obtains consent for email communications. You can opt-out of receiving promotional emails from us at any time by unsubscribing or by contacting us on our Website.
When you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technical and legal constraints. However, you will not continue to receive emails from the Company once you request removal of your name.
- Online Registration
You do not have to register to visit the Company’s Website. However, you may need to register and provide your Personal Information to be able to use some of the features offered through our online services. Your registration information is used to provide and administer the service you requested.
- Contests, Competitions, Co-Branded Participation, and Promotions
When you enter a contest, competition or participate in a promotion, we may collect your Personal Information. We use this information to administer the contest, competition or promotion including contacting, announcing and promoting prize winners. At the time you enter the contest, competition or promotion, we may obtain your consent to (i) send you future promotional communications, and/or (ii) disclose your Personal Information to a third party sponsor of the contest, competition or promotion, as specified at the time of collection of your Personal Information. We do not control the use, disclosure or security of your Personal Information by third party sponsors, and recommend that you review their privacy notices or statements (more information on third party sponsors is provided below).
- Third-Party Links
- Third Parties Acting on the Company’s Behalf
We will not transfer Personal Information to third parties, except to service providers who have agreed to comply with appropriate privacy standards, in order to perform services for the Company. We do not sell or rent our customer lists to outside agencies and/or our trade partners. Personal information supplied to us will not be used to place you on any mailing lists without your express consent.
- Market Research
We collect Personal Information for market research purposes. For example, we may ask you to provide postal code information or to participate in surveys or other customer research. Participation is voluntary. The information obtained through market research is used in an aggregated, non-personally identifiable form. We use this information to help us understand our customers, to enhance our product offerings, promotions and events. This information may be made available to third parties acting on behalf of the Company, who have agreed to comply with appropriate privacy standards.
- Customer Service and Call Recording
When you contact us with a comment, question or complaint, you may be asked for contact information that identifies you (such as your name, address and a phone number) and the information needed to help us answer your question or respond to your comment or complaint. We may monitor and/or record telephone discussions when you call us to enhance customer service, for training purposes and/or to confirm our discussions with you.
- Social Media and Networks
The Company may use accounts on social networks, including Facebook, Twitter, Instagram and others to promote its products and services. The Company’s social media accounts are publicly accessible, and your posts, comments, and replies to, and mentions of, the Company may be publicly visible, depending on your privacy settings. Your privacy and the retention of information on social media accounts are governed by the privacy policies of the parties that operate these social networks. Some social networks may allow you to control the information you make available to the Company and others. Users should review and agree to privacy agreements and terms and conditions of the parties that operate these networks prior to participating. As stated above, the Company does not have any control over such platforms, and therefore it has no responsibility or liability for the manner in which the organizations that operate such linked platforms collect, use, disclose, secure and otherwise treat your Personal Information. The Company may collect and measure information available to it about social media activity in order to provide content that is relevant and potentially interesting to users of these social media platforms.
- Cookies and Tracking Technology
Like many websites, the Company utilizes “cookies” to maintain a record of your visit to the Website and your use of the services. A cookie is a small text file that is transferred by a web server and stored on the hard drive of your computer or mobile device. It can only be read by the server that sent it to you. This information does not identify you personally and you remain anonymous unless you have otherwise provided the Company with Personal Information.
Cookies help us improve the Website and our services, and deliver more personalized service by enabling us to estimate audience size and usage patterns; to store information about your preferences; to speed up your searches and to recognize you when you return to the Website or use our services. Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your Internet browser’s steps for doing so. Please note, however, that if you do disable cookies from your browser, some pages of the Website may not function properly.
- Non-Personal Data Aggregation
The Company may use Personal Information that you provide to it for the purposes of research, to inform operations, and for communications planning. This data may be made non-personally identifiable by aggregating your information with data pertaining to other individuals, or removing personally identifiable details. Aggregate information obtained through cookies may be disclosed to third parties, but no Personal Information that identifies you will be released.
- Security and Protection of Personal Information
The Company maintains your Personal Information in a combination of paper and electronic files. Recognizing that your privacy is important, the Company employs technical and physical security measures to protect your Personal Information. Personal Information may only be accessed by persons within our organization who require such access to provide you with the services indicated above. However, no transmission over the Internet can be guaranteed to be completely secure since “perfect security” does not exist on the Internet. Consequently, the Company does not represent, warrant, covenant or guarantee the complete security of the Personal Information you provide to it.
We retain Personal Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements. We destroy Personal Information when it is no longer needed.
- Accuracy and Retention of Personal Information
The Company will make reasonable efforts to ensure the accuracy of your personal information when you request it as long as it does not compromise its privacy or security interest. Please contact us at the number below to update your Personal Information and account preferences. The Company will keep your Personal Information for as long as it remains necessary for the identified purposes or as required by law, or in accordance with our retention schedules, which may extend beyond the termination of our relationship with you. The Company reserves the right to maintain Personal Information records for both active and inactive/unsubscribed customers.
- Contact Information
If you have any questions concerning this Policy, please contact us at:
Telephone: (416) 488-2000
E-mail: [email protected]