Privacy Policy

Effective Date: May, 2024

Fraser Direct Distribution Services Ltd.  (“Fraser Direct”, “us”, “we” and “our”) is committed to protecting your privacy. 

This Privacy Policy explains how Fraser Direct collects, uses, and discloses personal information which is collected by, or provided to, Fraser Direct in the course of its business. We reserve the right to change the terms of this Policy at any time. When we make changes, we will revise the date at the top of this Policy. We encourage you to review this Policy periodically.

GENERAL INFORMATION

WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU, AND HOW DO WE USE IT?

“Personal information” means any information that can identify you, either on its own or in combination with other information. Fraser Direct does not collect sensitive personal information.

We may collect, or be provided by a third party, personal information including:

• Information Provided by Our Customers (Retailers and Other Businesses):
  Retailers or other businesses from which you have made a purchase may provide us personal information such as your:
  • Name
  • Address
  • Phone number
  • Email address

We use this personal information solely to perform our services in respect of products you have purchased from the relevant company. We may also use your contact information to contact you with respect to such services.

• Information You Provide to Us:
  In certain circumstances, you may provide us your personal information directly, such as when contacting our contact center or inputting payment details on a payment form. In such circumstances, we may collect personal information such as your:
  • Name
  • Address
  • Phone number
  • Email address
  • Payment data, such as a credit or debit card number, and the security code associated with your payment instrument.

    We use this personal information to facilitate your transaction including placing your order, scheduling shipment of your order, or facilitating returns. We may also use your contact information to contact you with respect to your order. To the extent we collect payment information from you, we will do so in accordance with all PCI-DSS requirements.

• Information Collected Automatically:
  When you access FraserDirect.net (fraserdirect.ca), we collect some information automatically. The technologies we use to assist with this data collection include cookies, web beacons, tags and scripts and software development kits. The categories of personal information we collect automatically include:
  • Identifiers and Device Information:
    Our servers automatically log information about the device you are using, including unique identifiers. The items we log include:
    • IP address
    • Cookie identifiers
    • Your browser language
    • Device identifiers

We may use this personal information for the following additional business purposes:

• Auditing: To ensure our internal processes work as intended, and comply with legal, regulatory, or contractual obligations.
  
  
• Fraud and Security Monitoring: To detect and prevent cyberattacks, bot activities, or other illicit activity within the services or website.

WHEN DO WE SHARE INFORMATION WITH THIRD PARTIES?

Except as set out in this policy, Fraser Direct does not disclose, or sell your personal information to any third parties. We may, however, share your information in the following circumstances:

• Service Providers:
  Fraser Direct may disclose your personal information to third-party service providers to perform certain services on our behalf, including:

• Fulfill orders and shipments.
• Provide technology and related infrastructure.
• Conduct audits.
• Analyze service usage.
• Assist in marketing.
• Processing payments.

For example, we may hire other companies to provide data storage, fulfill orders and shipments, assist in marketing, conduct audits, and so forth.

• Law Enforcement:
  Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
  
  
• Other Legal Requirements:
  We may disclose your personal information in the good faith belief that such action is necessary to:
  • Comply with a legal obligation.
  • Protect and defend the rights or property of Fraser Direct.
  • Prevent or investigate possible wrongdoing in connection with the services.
  • Protect the personal safety of users of the service or the public.
  • Protect against legal liability.

KEEPING YOUR INFORMATION UPDATED

We do not regularly update any personal information we collect from you. In the event it is necessary to update your personal information for the purposes for which it was collected, we will contact you to provide such updated information. You may also contact us to update your personal information.

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

We will only retain your personal information as long as is necessary for the fulfillment of the purposes for which it was collected or as required by law. Your personal information is securely stored until such time as it is no longer required, after which it is destroyed, rendering it unable to identify you.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We take the protection of your personal information seriously. We employ a range of safeguards designed to protect personal information against loss and theft as well as unauthorized access, disclosure, copying, use, and modification, including physical, organization and technological measures, commensurate with the sensitivity of your personal information. Our employees have access to your personal information only on a strict need-to-know basis, are trained in the proper handling of such information, and are required to keep such personal information confidential and use it only for the purposes for which it was provided.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any other purpose.  However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use these commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

WHAT ARE YOUR RIGHTS AND CHOICES?

We believe you to have the right to control the use of your personal information and provide methods to control the personal information we hold about you, including choices about how we use that information. Where noted for certain jurisdictions, these controls and choices are enforceable as rights under applicable law.

• Requests to Access, Correct, Modify, or Delete Personal Information:
  Based on your jurisdiction, you may have various rights to access, amend, delete, or otherwise obtain your personal information. You may update or amend your information at any time or request the exercise of other privacy rights by contacting us at privacy@fraserdirect.ca.

  Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

• Do Not Track:
  Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
  
  
• Appeals:
  If we refuse to take action on your exercise of choices described in this Privacy Policy, you can appeal such a refusal by contacting us at privacy@fraserdirect.ca.

You may exercise your rights by contacting us at  privacy@fraserdirect.ca. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

BUSINESS TRANSFERS:

In the event of any acquisition or sale of Fraser Direct and/or its assets, we may be required to disclose your personal information to a purchasing entity. We reserve the right to disclose your personal information if required or permitted to do so by law. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

RIGHTS FOR CALIFORNIA RESIDENTS

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

NOTICE AT COLLECTION

At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how long such information is retained. You can find those details in this Privacy Policy under the “GENERAL INFORMATION” section.

RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT AND THE CALIFORNIA PRIVACY RIGHTS ACT

The California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA”) provides California residents with the following specific rights regarding their personal information:

• The Right to Know/Access:
  Under CCPA you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purposes for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we disclosed your personal information for a business purpose, we will disclose to you the personal information categories disclosed.
    
    
• The Right to Opt-Out of Sharing of Personal Information:
  You have a right to opt-out from the “sharing” of your personal information with third parties who are not our service providers.
  
  
• The Right to Correct Personal Information:
  You have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our service providers to correct, if applicable) your personal information, unless an exception applies.
  
  

• The Right to Delete Personal Information:
  You have the right to request the deletion of your personal information under certain circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete, if applicable) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
    
    
• The Right to Non-Discrimination:
  You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
  • Denying goods or services to you.
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties.
  • Providing a different level or quality of goods or services to you.
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

EXERCISING YOUR RIGHTS UNDER THE CCPA

You may exercise your rights under CCPA by contacting us at  privacy@fraserdirect.ca. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request; and
• Confirm that the personal information relates to you.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

DO NOT SELL MY PERSONAL INFORMATION

As defined in the CCPA, “sell” and “sale” includes making a consumer’s personal information available to a third party for other valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow service providers to use your personal information for the business purposes described in our Privacy Policy, and these may be deemed a sale under CCPA.

You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop “selling” (sharing) your personal information. To exercise your right to opt-out, please contact us.

SHINE THE LIGHT PRIVACY RIGHTS

Under California’s Shine the Light law, California residents can opt out of our sharing of their information to third parties, and in certain circumstances affiliates, for their direct marketing purposes.

If you’d like to request more information under the California Shine the Light law or opt-out of such sharing, please contact us.

CHILDREN’S PRIVACY

Fraser Direct’s website is intended for a general audience and is not directed at children under 13 years of age. We do not knowingly collect personal information from anyone under the age of 13. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us. We will remove the data to the extent required by applicable laws.

HOW TO CONTACT FRASER DIRECT

If you would like to know more about our privacy practices or if you would like to exercise certain rights under this policy, please contact our Privacy Officer by:

Email: privacy@fraserdirect.ca

Mail: 8300 Lawson Rd, Milton, ON, L9T 0A