Canada Privacy Policy
Last Updated: OCTOBER 1, 2021
California Closet Company, Inc. (“we,” or “us,” or “our”) cares about your privacy and recognizes the importance of protecting your Personal Information (as defined below). This Privacy Policy describes the kind of information we may collect during your visit to our websites, use of our mobile applications, and during any other interactions you may have with us in connection with our business (collectively, the “Services”). This Privacy Policy also describes how we use, protect and disclose your information, and your options with respect to that information.
Personal Information
We collect, use and disclose various types of Personal Information. For purposes of this Privacy Policy, “Personal Information” means information about an identifiable individual. It does not include de-identified or aggregate information or certain publicly available information.
Your Consent
BY PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY POLICY.
We may use and disclose your Personal Information in accordance with the consents that you provide, whether explicit or implied, as well as may be set out in this Privacy Policy.
Form of Consent
When we collect, use or disclose your Personal Information we will generally obtain your consent. Most of the time, we will obtain your consent before or at the same time we collect your Personal Information. In some instances, however, we may seek your consent after we have collected your Personal Information if we wish to make an additional use or disclosure of your Personal Information where we do not already have your consent for that new use or disclosure.
Depending on the circumstances, your consent may be express or implied. Express consent would arise if you specifically consented to a particular dealing in your Personal Information. Express consent can be given orally, electronically or in writing.
Implied consent can be inferred from the circumstances and, in particular, where the uses and disclosures are readily apparent at the time we collect the Personal Information. For example, if you send us an email requesting certain information, we will use the email address in your email to send you the requested information without asking you if we can use the email address for that purpose, your consent will be implied in those circumstances. We will assume your consent to the collection, use and disclosure of your Personal Information for a particular purpose if you voluntarily provide the information for that purpose.
This Privacy Policy also describes certain instances in which we may collect, use and disclose your Personal Information. By providing Personal Information in connection with the Services, we will assume that you have consented to the collection, use and disclosure of Personal Information in accordance with the terms set out in this Privacy Policy unless you inform us in writing otherwise. For greater certainty, if you do not consent to certain collection, use and disclosure of your Personal Information, it may limit the manner in which you can make use of the Services and to otherwise interact with us.
Certain Personal Information We Collect, From Where We Collect It, Why We Collect It, and With Whom We Share It
The following chart describes certain categories of Personal Information we may collect about you and, for each category, where and why we collect it, and the categories of entities with which we may share your Personal Information. By providing Personal Information to us, we will assume that you have consented to the collection, use and disclosure of Personal Information in accordance with the following chart unless you inform us otherwise.
| Categories of Personal Information |
Categories of Sources | Purpose(s) for Collection of Personal Information |
Categories of Third Parties with Which Personal Information is Shared for a Business Purpose |
|---|---|---|---|
| Personal Identifiers – such as name, postal address, Internet Protocol address, mobile ad ID address, email address, driver’s license number, estimated home value, estimated household income, phone numbers, emergency contact information, age, gender, marital status, or other similar identifiers |
|
|
Service providers (vendors that provide services to us in connection with the operation of our business, which can include vendors that process payments and customer approvals, verify customer information, manage customer information, facilitate scheduling, facilitate email communications, facilitate texting communications, advertising and marketing of our products and services and those of our affiliates, manufacture and fulfillment of orders, warranty services, provide security services, cloud-based data storage, host our webpage and assist with other IT-related functions, advertising and marketing, provide analytics information, legal and accounting services, among other business functions) Franchises |
| Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
|
|
Franchises
Company owned locations Company-owned affiliates |
| Internet or other electronic network activity information, including browsing and search history, |
|
|
Service Providers |
| Geolocation data |
|
|
Service Providers |
| Audio information |
|
|
Franchises
Company owned locations Company-owned affiliates Service Providers |
| Inferences drawn from Personal Information to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
|
|
|
Franchises and Company-owned Outlets
Many of the services of California Closet Company, Inc. are provided through independently-owned and operated franchises as well as through company-owned locations and company-owned affiliates. In that regard, we provide a number of services to support our franchises and company-owned outlets. As such, a franchise or company-owned outlet may provide your Personal Information to us to enable us to assist that franchise or company-owned outlet with its operations and, as such, we may use your Personal Information in order to provide that assistance. Some instances where a franchise or company-owned outlet may provide your Personal Information to us are set out in the chart above.
Service Providers
We may engage certain service providers. Those service providers may provide services to us to assist us in our activities. Other service providers may provide services directly to you at our request. As such, it may be necessary to disclose your Personal Information to these service providers. Some instances where we may provide your Personal Information to a service provider are set out in the chart above.
We will take reasonable steps to ensure that these service providers only use and disclose your Personal Information as necessary to provide the services and that they will adhere to the terms of this Privacy Policy.
Storage and Processing Information Outside Canada
Certain of our affiliated companies are located in the United States. As well, certain of our service providers are located outside of Canada. As such, we may transmit your Personal Information to our affiliated companies and to third parties who are located outside of Canada to assist us in the operation of our business. By providing Personal Information to us, you are consenting to the delivery and the storage, processing and handling of your Personal Information outside of Canada. Please note that many governments around the world can require that organizations under their jurisdiction deliver information, including Personal Information, that is in the control of that organization to the government. This is often done without notice to or the consent of the affected individual.
Marketing
With respect to each of the categories of Personal Information we collect as noted in the chart above, we may use your Personal Information to market products and services that we think may be of interest to you, including our own products and services as well as those of our affiliates and the products and services of third parties.
Additional Information Regarding Our Collection, Use and Sharing of Personal Information
Privacy law permits or requires the collection, use and disclosure of Personal Information without the knowledge or consent of the individual in certain circumstances. We reserve the right to collect, use and disclose your Personal Information in these circumstances without your knowledge or consent, including in one or more of the following circumstances: in order to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites and mobile apps, or the public.
We may monitor your use of our websites and mobile applications to ensure the proper use and operation of the same and your compliance with any terms of use related to our websites and mobile applications or other related agreements and in connection with the protection of the security and safety of our business, computer systems, software, Personal Information and data.
We may also share Personal Information with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.
Our Use of Cookies, Web Beacons and Analytics
We may send text files (e.g., “cookies” or other cached files) to your web browser. Such text files are used for technical convenience to store information on your computer. For instance, we may use a cookie to store form information that you have entered so that you do not have to enter such information again. As well, we may use web beacons (also known as web bugs or pixel tags) which lets us know when you access our content and will provide certain information to us, including your IP address, the time of access, type of web browser or email client you are using and the existence of cookies we may have previously set. We can then associate this information with an existing cookie. We may use information stored in cookies and cached files to customise your experience with the Services and to monitor your use of the Services. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.
Google Analytics
We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit the website, what pages they visit, when they do so, and what other websites they visited prior to visiting our website. Google Analytics may collect your IP address, data related to the device/browser you are using, and other information about your use of our website. Google Analytics provides us with statistical information about the use of our website. We use this information to understand our visitors and to improve the website. We cannot associate any of this information with any particular visitor.
Google Analytics collects information on your activities on our website and may associate it with other information that they may have collected and they may use all of this information for their own business purposes. See https://policies.google.com/technologies/partner-sites for more information on Google’s privacy practices with respect to websites that use Google services.
Do Not Track
“Do Not Track” is a privacy preference that users can set in certain web browsers. We do not comply with automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
Personal Information of Minors
Our products and Services are not directed to minors under the age of 13 and we do not knowingly collect or sell the Personal Information of minors under 16.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
Personal Information of Others
You may not provide to us any Personal Information of others unless you have the consent of those individuals or you are otherwise permitted by law to provide us with their Personal Information.
Requests for Access to Personal Information
On your written request we will provide you with:
- access to your Personal Information (if any) under our custody or control;
- information about the purposes for which your Personal Information under our custody or control has been and is being used by us; and
- the names of persons to whom, and the circumstances in which, your Personal Information
has been and is being disclosed by us.
All requests may be subject to reasonable fees and disbursements. Where appropriate to do so, we may require advance payment of a deposit or the entire costs of responding to a request for access to Personal Information.
Requests Must be in Writing
We require that all requests for access be in writing and be signed by the requestor. We required sufficient information and detail from the requestor in order to verify identity, properly locate the information and respond to the request.
Limits on Individual Rights to Information
An individual’s ability to access his or her Personal Information under our control is not absolute. We reserve all rights to not disclose Personal Information, or its existence, in certain circumstances. For example, we may not disclose Personal Information where:
- the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual;
- the disclosure would reveal Personal Information about another individual;
- the disclosure of the information would reveal confidential commercial information; or
- the Personal Information was collected by us for an investigation or legal proceeding.
Requests for Correction of Personal Information
On request by you, we will correct errors or omissions in your Personal Information where that information is in our custody or control. We require that all such requests be in writing and signed by you. We may require sufficient information and detail from the individual in question in order to verify identity, properly locate the information and respond.
If you make such a request, we will either:
- correct the Personal Information and, if reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect information; or
- decide not to correct the Personal Information, but we will retain a record that a correction was requested but not made.
Corrections or amendments will rarely, if ever, be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.
Our Commitment to Honoring Your Rights
If you exercise any of your rights described in this Privacy Policy, we will continue to treat you fairly.
Changes to This Privacy Policy
We will review and update this Privacy Policy as required to keep current with rules and regulations, new technologies and security standards and changes to our business and privacy practices. We will post the updated Privacy Policy to the website and we will update the Privacy Policy modification date set out at the top of this Privacy Policy. In certain cases, and if the changes are material, we will post notice of the changed Privacy Policy on our website and we may notify you by email if we have your email address. The amended Privacy Policy shall automatically be effective when posted. Your continued dealings with us or use of the Services following the posting of the amended Privacy Policy means that you accept the terms of this Privacy Policy as amended. If you disagree with any of the amended Privacy Policy then you must immediately cease all use of the Services and cease dealing with us.
The first sentence of this Privacy Policy indicates with this Privacy Policy was last amended. Please check back regularly to review for changes.
Limited Nature of this Privacy Policy
Nothing contained in this Privacy Policy is intended to create a contract or agreement between you and us and you may not rely on it as such.
Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at privacyrequests@calcosets.com or 800-225-2567.
Contact Us
If there are any questions regarding this Privacy Policy or our privacy practices or to request a copy of this Privacy Policy in another format you may contact us using the information below:
California Closet Company, Inc.
Attn: General Counsel
2043 W. Lone Cactus Drive
Phoenix, AZ 85027
privacyrequests@calclosets.com
1-800-225-2567
You may also contact our Data Privacy Officer:
Kenneth Martin