Last updated: 21 May 2014
This Policy applies to personal information we collect in the course of operating our business in Canada, including at our Canadian retail stores and online through the Canadian versions of the Waterford.com, Wedgwood.com, RoyalDoulton.com and RoyalAlbert.com websites operated by WWRD Canada (referred to as the "WWRD Canada Websites"). The WWRD Canada Websites are intended for use of persons residing in Canada and for delivery of products and services within Canada. This Policy does not apply to any information that is exempted from the definition of "personal information" in applicable privacy legislation.
The WWRD Canada Websites may contain links to other websites. WWRD Canada is not responsible for the privacy practices of other websites. We encourage you to read the privacy policies and statements of such other websites that collect your personal information.
WWRD Canada is accountable for all personal information under its control. This includes personal information under our direct control, as well as personal information that we may transfer to our affiliates or third party service providers for servicing, processing, storage or other purposes that facilitate our business operations. We use contractual or other appropriate means to require third parties that provide services on our behalf to maintain a level of privacy protection comparable to our own practices.
Numerous individuals within WWRD Canada are responsible for the day-to-day collection and processing of personal information including our sales associates and account and administrative personnel. WWRD Canada has designated a Privacy Officer who is accountable for the handling of all personal information under WWRD Canada’s control and for ensuring that the principles set out in this Policy are complied with.
Collection, Use and Disclosure of Personal Information
Personal information is information about an identifiable individual. The personal information we collect may include information such as your name, billing address, shipping address, telephone numbers, email address, and credit and debit card information. In some cases, such as when you ask us to ship an order or you purchase a gift or gift messaging, we may collect information about someone other than you, such as the name, address, telephone number and email address of the recipient.
Either before or when we collect personal information from you, we will explain how we intend to use and disclose it. We will limit the collection of personal information to that which is necessary to accomplish the identified purposes and will use and disclose it only for those purposes. If we wish to use or disclose your personal information for a new purpose, we will identify such purpose and obtain your consent prior to use or disclosure for such purpose, unless such consent is not required by law.
How We Collect Your Personal Information
We collect personal information from you in a variety of ways when you interact with WWRD Canada. Some examples include but are not limited to situations when you:
- Create an account on one of the WWRD Canada Websites;
- Order, purchase, exchange, return or cancel an order for any of our products or services;
- Contact us or make an inquiry about any of our products or services;
- Communicate with our customer service representatives;
- Sign up to receive email newsletters and information about new products, special offers, events or other news;
- Participate in a contest, promotion or survey;
- Apply for employment through one of the WWRD Canada Websites or at a store;
- Visit or use one of the WWRD Canada Websites;
- Engage with us on social media.
WWRD Canada may also conduct video surveillance of its stores and other premises for security and loss prevention purposes.
In most cases, we collect personal information directly from you. However, in some cases, we may obtain personal information about you from other sources. Unless there is a legal exception, we will obtain your consent to the collection of personal information about you from other sources.
We automatically collect certain types of information whenever you interact with us. For example, when you visit the WWRD Canada Websites our systems automatically provide us with your IP address and tell us what type of web browser you use. This information may be linked to personally identifiable information if you have registered with us in the "My Account" section of the WWRD Canada Websites. Unless linked with personally identifiable information, this usage is not subject to the terms of this Policy.
Tracking Technologies. We may use various methods and technologies to store or collect usage information ("Tracking Technologies"). Tracking Technologies may set, change, alter or modify settings or configurations on your device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed).
Cookies. A cookie is a data file placed on a device when it is used to visit the WWRD Canada Websites. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in the WWRD Canada Websites’ pages and messages.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the WWRD Canada Websites, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the WWRD Canada Websites, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).
Location-identifying Technologies. Additionally, the WWRD Canada Websites may use GPS (global positioning systems) software and other location-based technologies such as iBeacons to locate you so we may verify your location, deliver your relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the WWRD Canada Websites.
How We Use Your Personal Information
WWRD Canada uses your personal information to offer and provide products and services (including to process and track orders, shipping, payment, etc.), manage our relationship with you, verify your identity and address, carry on our business operations and as may otherwise be required or permitted by law. Some examples include, to:
- Fulfill your requests for products and services and communicate with you about those requests;
- Administer your account;
- Provide you with newsletters, catalogues, brochures and information about our products, services, promotions and other events;
- Administer contests, promotions and surveys;
- Provide customer service;
- Perform data analysis services;
- Help us improve and customize our service offerings, websites and advertising;
- Protect against error and fraud;
- Protect the security and integrity of our websites and our business;
- Process and respond to applications for employment;
- Meet legal requirements.
How We Disclose Your Personal Information
WWRD Canada will not trade, rent or sell your personal information to third parties. We will only disclose your personal information with your consent or under the following circumstances.Affiliates
We may share personal information that we collect within our affiliated group of companies for the purposes identified in this Policy.Service Providers
We may disclose or otherwise make available personal information to third party service providers that help with our business operations, such as third parties who perform services for us such as shipping of products, payment card processing, credit account verification or who support the technical operation and maintenance of our Websites. We require all such service providers to keep your information confidential and secure, and to have privacy policies and practices with respect to personal information that are comparable to ours. In addition, we require that our service providers not use or disclose the personal information for any purpose other than providing the services on our behalf, except as may be required by law.Sale of Business
WWRD Canada may transfer any information we have about you in connection with a potential or actual merger, amalgamation, acquisition, disposition or sale, of all or part of our business or assets.Legal Requirements
WWRD Canada may also disclose your personal information as required or permitted by law, including, without limitation, to assist us in collecting any debt owed by you, to comply with a subpoena, warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law.
Your personal information may be processed and stored in any country in which our affiliates or our service providers maintain facilities and may be accessible to the government, courts or law enforcement or regulatory agencies of any such country through the laws of such country.
Depending on the circumstances and the sensitivity of the information, we may obtain your consent to the collection, use and disclosure of your personal information in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained when you approach us to obtain information, inquire about or order products or services from us, or through your use of a product, service or one of the WWRD Canada Websites.
You may withdraw your consent to our collection, use, and disclosure of your personal information at any time, on reasonable notice, subject to legal or contractual restrictions. We will inform you of the implications of doing so. For instance, withdrawal of consent may make it impossible for us to provide certain products or services to you.
If you have opted-in to WWRD Canada’s email list to receive newsletters, you may unsubscribe from such emails online at a WWRD Canada Website, by using the subscribe mechanism included in any such email, or otherwise by contacting WWRD Canada customer service by any of the means indicated on the WWRD Canada Websites.
We will not refuse to provide a product or service to you if you choose not to provide us with your personal information, unless the failure to provide such information makes us unable to provide such product or service to you.
Retention and Security of Personal Information
WWRD Canada has implemented policies and procedures as to how long it retains personal information it collects. WWRD Canada will retain personal information for as long as necessary for the fulfilment of the identified purposes, or as otherwise required or permitted by law. Personal information that is no longer required to fulfill the identified purposes is either destroyed, erased or rendered anonymous to prevent unauthorized parties from gaining access to the information.
WWRD Canada has implemented security safeguards, appropriate to the sensitivity of the information, to protect personal information in our control against loss, theft, as well as unauthorized access, disclosure, copying, use, or modification. These security safeguards include organization, technical and physical measures such as:
- Premises security;
- Restricted file access to personal information;
- Technological safeguards including security software and firewalls to prevent hacking and other unauthorized computer access;
- And internal password and security policies.
We also takes the following measures to help protect your personal information online.
When you place an order or create an account on a WWRD Canada Website, your personal information is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your information before transmitting it to our server. SSL technology, an industry standard, is designed to prevent someone other than operators of WWRD Canada Websites from capturing and viewing your personal information. If your browser cannot support SSL, you will not be able to order products or register or sign-in through our Websites.
If you create an account on a WWRD Canada Website, your account information is protected by the password you use to access your online account. We strongly recommend that you do not disclose your password to anyone. WWRD Canada will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls or email messages).
Access to and Accuracy of Personal Information
If you are a registered user of a WWRD Canada Website, you can access, review and update your profile, contact information and email/marketing preferences at any time by clicking on the "My Account" link at the top of any page on the site.
You may also request access to your personal information in our custody or control, and an account of our use and disclosure of that information, by contacting our Privacy Officer in writing. In order to verify that the information is being released to the proper individual, you may be asked to provide suitable identification or to otherwise identify yourself. We will advise you in advance if a minimal charge will apply and we will respond to your request within 30 days. If we are unable to provide you with a list of organizations to which we have actually disclosed your personal information, we will provide you with a list of organizations to which we may have disclosed your personal information. In certain circumstances, access to personal information may be denied. If we deny your request for access to your personal information, we will advise you in writing of the reason for the refusal, unless we are prohibited by law from doing so.
You are entitled to challenge the accuracy and completeness of your personal information and have it amended as appropriate. In most cases, WWRD Canada relies on you to provide any updates to or correction of your personal information. Where personal information is used on an on-going basis, WWRD Canada undertakes to correct any information that is shown to be inaccurate, incomplete, or not up-to-date. Otherwise, we do not routinely update personal information unless it is necessary to fulfill the purposes for which the information is collected. Upon request from you to have any or all of your personal information in our records deleted or destroyed, WWRD Canada may undertake to use reasonable efforts to do so to the extent such information is not required to be retained by law or for any other lawful business purpose, such as the investigation of claims or defence of an action.
Our policies and procedures are reviewed periodically and, as such, we may change this Policy from time to time. Please check this Policy periodically for changes. We will post the most up-to-date version of this Policy on the WWRD Canada Websites and indicate the date it was last updated at the top of the Policy.
Contact Our Privacy Officer
If you wish to challenge our compliance with this Policy or have any questions, comments or concerns about this Policy or our privacy practices, please contact WWRD Canada's Privacy Officer using the contact information shown below. All complaints will be investigated. If WWRD Canada finds a complaint to be justified, appropriate measures will be taken, including if necessary, amending our policies and practices.
WWRD Canada, Inc.
Attn: Privacy Officer
PO Box 1454
Wall, New Jersey 07719-1454 USA
If you are not satisfied with our response, the Office of the Privacy Commissioner of Canada (OPCC) investigates complaints under the Personal Information Protection and Electronic Documents Act (PIPEDA). The OPPC can be reached at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3