Last revised: July 10, 2019
- any other products, services, interactive features, widgets, and resources offered or provided by us such as offline customer service and order fulfillment (all of which are collectively referred to as the "Services").
Attn: Legal Department
PO Box 34585 Place St-Laurent
St-Laurent QC H4R 2P4
INFORMATION WE COLLECT
We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
- Personal Identifiers (e.g., name, IP address, login username & password)
- Personal Characteristics (e.g., gender, marital status)
- Contact Information (e.g., mailing address, email address, phone number, fax number)
- Commercial Information (e.g., shopping and purchase history)
- Financial Account Information (e.g., credit card number, checking account number)
- Internet or Other Electronic Network Activity (e.g., browsing history, search history, other information regarding your use of our Website(s) or Services that can be associated with you)
- Professional or Employment-Related Information (e.g., occupation, employer)
- Inferences drawn from the above categories of Personal Information that relate to your characteristics and preferences.
To provide the Website(s) and perform the Services offered, we may need to collect and distribute your Personal Information to our trusted business partners who fulfill the services you request. If such information is capable of being personally associated with you, we will treat it as Personal Information, otherwise we will treat it as Usage Data.
The collection of personal information will be limited to that which is necessary for the purposes we identify. Information will be collected by fair and lawful means and may be collected from other sources including but not limited to credit bureaus or other third parties who represent that they have the right to disclose the information.
Usage Data and Site Activity
We automatically collect information in connection with the actions you take on the Website(s) and in connection with using the Services ("Usage Data"). For example, each time you use the Website(s), we automatically collect the type of web browser you use, your operating system, your Internet Service Provider, the pages you view, and the time and duration of your visits to the Website(s).
We are responsible for personal information under our control and as a result has designated an individual as the person who is accountable for our compliance with our privacy principles (“Privacy Officer”). As such:
- accountability for our compliance with the principles rests with the Privacy Officer, even though other individuals within our organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within our organization may be delegated to act on behalf of the Privacy Officer;
- the identity of the Privacy Officer we designate to oversee our compliance with the principles will be provided to you upon request; and
- we are responsible for personal information in our possession or custody, including information that has been transferred to a third party for processing. We shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
HOW WE COLLECT INFORMATION
We may ask you to provide us with Personal Information when you register with the Website(s), make a purchase, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Website(s) or Services or we may not be able to fulfill your purchase.
From time to time we, or third parties retained by us, may request Personal Information from you via surveys. Participation in these surveys is completely voluntary and you have a choice whether to disclose Personal Information. The requested information typically includes contact information (such as name and address), demographic information (such as postal code), and product usage and preferences.
Third-Party Data Sources
We collect Personal Information from third-party data sources such as the United Parcel Service and data brokerage companies. This Personal Information may be appended to Personal Information we have already collected from or about you to create a “profile” for you.
We use the following types of cookies:
- Cookies: Session cookies keep track of you or your information as you move from page to page within the Website(s) and are typically deleted once you close your browser. For example, session cookies allow your online shopping cart to function properly.
- Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Website(s). For example, persistent cookies may allow us to remember your preferences.
- Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you. For example, if you look at many pens on our Website(s), we may infer that you are interested in pens and send you advertisements about pens.
Online Behavioral Advertising
Tracking Pixels and Clear GIFs
We employ software technology that enables us to track certain aspects of a user's visit to the Website(s). This technology helps us better manage content on the Website(s) by informing us what content is effective, how consumers engage with the Website(s), and how consumers arrive at and/or depart from the Website(s). The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session, such as IP addresses and the type of browser used, and Personal Information, if provided by the user.
Google Analytics Advertising Features
We have implemented certain Google Analytics Advertising Features, including Google Analytics Demographics and Interest Reporting and Remarketing with Google Analytics. We use first-party cookies (such as the Google Analytics cookie), along with other first-party identifiers, third-party cookies (such as the DoubleClick cookie) and other third-party identifiers, not only to improve the site experience for our users, but also to aggregate the characteristics and browsing habits of our users, on an anonymized basis, to provide products and services that are more tailored to our users. We also use these types of cookies and identifiers to improve and target our marketing and remarketing efforts and serve ads based on our users' prior visits to our website.
Social Media Widgets
The Website(s) may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with social media features are governed by the privacy policies of the companies that provide them.
HOW WE USE AND SHARE INFORMATION
Your personal information will not be used or disclosed for purposes other than those for which is was collected, except with the your consent or the consent of the individual whom the information is about, or as required or permitted by Privacy Laws or other applicable laws.
We may use your Personal Information for internal purposes, such as to:
- Provide you with the Website(s) and Services;
- Process or complete transactions you requested;
- Improve the Website(s) and Services, including customization and personalization;
- Enhance your experience with the Website(s) and Services;
- Notify you of new products and services via mail, email, telephone, and/or text messaging;
- Develop and present to you recommendations and advertisements regarding our products and services;
- Communicate with you about the Website(s), Services, and other matters via mail, email, telephone and/or text messaging; and
- Compile anonymous information and analyses.
If you provide a testimonial, we may post it publicly on the Website(s) or in other advertising material without notice to you.
From time to time, we may establish a relationship with other businesses that we believe are trustworthy and have privacy practices consistent with ours which may include corporate affiliates (“Service Providers”). We contract with Service Providers to provide certain services to us, including:
- Online hosting and maintenance;
- Marketing and promotion design and management;
- Payment processing;
- Management of access to services;
- Data storage and management; and
- Identity and contact information validation.
We may provide Service Providers with Personal Information only to the extent necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We share the following types of Personal Information with one or more Service Providers: personal identifiers; personal characteristics; contact information; commercial information; financial account information; internet or other electronic network activity; professional or employment-related information; inferences drawn from the above categories of Personal Information that relate to your characteristics and preferences.
We do not share your Personal Information with third-party companies to market their products or services to you. Please note that your information may still be shared with certain third parties for transactional purposes such as fulfilling products and services you have requested.
We may use your Personal Information to market products or services likely to be of interest to you, or to provide you with special offers and opportunities, via email. With respect to commercial email communications from us, you may opt out of these emails via a link in the footer of all commercial email messages.
We recognize the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we employ reasonable administrative, technical and physical safeguards to protect such personal information from unauthorized access, disclosure and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Website(s) we cannot, and do not, guarantee the security of any information you transmit on our Website(s), and you do so at your own risk. Your information is stored on our servers located in the United States. We use industry standard safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy.
Please be aware that third-party websites accessible through the Website(s), including websites/webpages of affiliated companies that are not domiciled in the United States, may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information through linked websites.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, users, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax and/or accounting obligations. We do so in accordance with our data retention policies and applicable law.
The Website(s) are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.
ACCCESS & CORRECTION
If you would like to receive access to your transaction information and/or request the correction of inaccurate information, you may do so by calling us at 1-800-595-9547, sending an email to CustomerCare@pens.com or sending a written request to the following postal address:National Pen Co., LLC
Attn: Legal Department
PO Box 34585 Place St-Laurent
St-Laurent QC H4R 2P4
ADDITIONAL CONSUMER RIGHTS
Right to Know
You have the right to request that we provide you (i) the categories and specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; and (iv) the categories of third parties with whom we shared your Personal Information. If we sold or disclosed your Personal Information to third parties, you also have the right to request that we provide you (i) the categories of Personal Information we collected about you; (ii) the categories of your Personal Information we sold to third parties; (iii) the categories of third parties to whom we sold your Personal Information; and (iv) the categories of your Personal Information we disclosed to third parties.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, comply with legal obligations, or perform other functions permitted by law.
Exercising your Rights to Know, Access, and Deletion
You may exercise your Rights to Know, Access, and Deletion by calling us at 1-800-595-9547 or sending an email to CustomerCare@pens.com. Please be specific in your request and provide sufficient information to allow us to locate your Personal Information in our systems based on your request. We may request additional information from you in order to verify your identity or locate your Personal Information. We will respond to your request within 45 days, but we may extend the time for response by an additional 45 days if an extension is reasonably necessary and we inform you of the extension. You may request the same type of information up to two times in a 12-month period.
No Sale of Personal Information
We do not sell your Personal Information to third parties.