Last Updated: April 11, 2019
Changes to this privacy notice
We will update this privacy statement when necessary. When we post changes to this statement, we will revise the “last updated” date at the top of the statement and highlight what has changed. If there are any changes as to how ThruFlow use will use your personal data, we will notify you by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how ThruFlow is protecting your information.
The bases that we rely on
There are several different reasons why a company can collect and process your personal data. The bases that we use as a company are:
Where we have a contract with you, we will use your personal data to fulfil the contract.
In some cases, the law requires us to collect and pass on your data, for example we pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you direct marketing information about products and services that are available, and we believe are of interest you.
In certain situations, we will have obtained consent to contact you about our products, services and promotions and we will contact you only according to the consent you have provided.
How and why we use personal data
ThruFlow collects and uses personal data only as necessary for the purposes for which is was obtained. We may use your personal data for some or all of the following purposes:
- Orders – We need your personal data to comply with our contractual obligations so that we can manage your customer account and provide you with the goods and services you want to buy, including sending any relevant and necessary documentation and communications regarding the product or service and help you with any orders and refunds you may ask for. Sometimes we may need to share your details with a third party who is providing a service (such as delivery couriers or a fitter visiting your home). We do this to be able to fulfil our contract with you.
- To allow you to pay for the goods and services that you have received - In order pursue our legitimate interests we may need to contact you to take payment or pass your details onto third parties for debt collection purposes.
- Consumer Service – to provide you with consumer service, including response to your inquiries, complaints, and general feedback about our products. Consumer service may be provided through various forms of communication including via email, letter, and telephone.
- Consumer Engagement – to get you more actively engaged with our products and services. This may involve the use or publication of consumer-generated content.
- To comply with our legal obligations –
- In some cases, we will need to process your personal data to comply with our legal obligations. For example, before we can discuss personal data, we will need to verify the identity of the individual we are talking to.
- To send you communications required by law, or which are needed to inform you about changes to products or services that have been provided to you. For example, updates to this Privacy notice, product recall notices or information we are legally required to communicate to you regarding your order. These messages will not include any marketing content.
- To comply with any legal obligations to share data with law enforcement, for example if a court order is submitted to us requiring that we share your personal data.
When we collect personal data, and what we collect
This section lets you know under what circumstances we may collect personal information from you, and what personal data we may collect.
When you complete the Contact Us page, we ask you to provide Personal Information. Depending upon the activity you are attempting to complete, this may include any of the following:
- E-mail address
- Phone number
When you browse our websites, we may collect using Google Analytics:
- Information about the device you have used to access the Website (including the make, model and operating system, IP address, browser type and mobile device identifiers)
- Your IP address is a unique identifier used to identify the computer or device that you are using to access the internet.
- Information about your online browsing behaviour on our Website, including which site you came from and products that you are interested in, and information about when you click on one of our adverts, including those shown on other organizations’ websites.
When you contact us (including via social media) we may collect:
- Personal data you provide about yourself any time you contact us about our Services (for example, your name, social media username and contact details), including by phone, email or post or when you speak with us through social media
- Details of your interactions with us through phone, exhibitions, or in-person. For example, we may collect notes of conversations with you, details of any complaints or comments you have made and copies of emails that you have sent us.
When you take part in any promotions or competitions of ours, or chose to complete any surveys we send you
- Your feedback and contributions to customer surveys and questionnaires
- Details of the promotion, including your responses and any prizes won.
When you comment on or review our products and services online
- Your comments and product reviews if posted online.
It is important that personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us. Our contact details can be found at the end of this privacy notice or at the ‘Contact Us’ tab of our website.
How we protect your data
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by employees in the performance of their duties.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
How long we keep your data for
We will not keep your personal data for longer than is necessary for the purpose or purposes that it was initially collected. At the end of that retention period, your data will either be securely deleted or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who we share your personal data with
We may disclose your personal data to any member of our ultimate holding company ThruFlow Inc. insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
We work with carefully selected Third Parties – such as ThruFlow™ distributors, contractors, OEMs and retailers – that carry out certain functions on our behalf. These include, for example, companies that carry ThruFlow products and sell direct to end-users, technology services, processing payments and delivering orders. We only share personal data that enable our Service Providers to provide their services. For example, providing your contact information to a dealer who will service your order.
We apply the following policy when we share your personal information with external organizations
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is always respected and protected.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
We may disclose your personal data on the basis of our legitimate interests to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Financial transactions relating to our website and services are handled by our payment services providers. We share your information with them in so that we can process your payments, and deal with complaints and queries relating to these payments and/or refunds.
What are your rights?
You have the right:
- To ask us not to process your personal data for marketing purposes;
- To ask us not to process your personal data where it is processed based on legitimate interests provided there are no compelling reasons for that processing;
- To request from us access to personal information held about you;
- To ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
- To ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation;
- To ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
Where use of your personal data is based on consent, you can withdraw that consent at any time.
How to stop the use of your personal data for direct marketing
You can stop direct marketing from us several ways:
- Click the ‘unsubscribe’ link included in all emails we send you. We will then stop any further emails from that division.
- Telephone the main office toll free on (855) 697-7267 or email [email protected].com to opt out of receiving telephone, mail, or direct mail.
- Write to us at ThruFlow Marketing, 700 Gillard Street, Wallaceburg, Ontario, CANADA N8A 4L3.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Subject to Access Request
Under PIPEDA in Canada, you have the right of access to your Personal Data held by us so that you are aware of and can verify the lawfulness of our processing activities.
In some cases, we may be entitled to refuse to respond, if this is the case, we will inform you of our decision and the reason for it. You are then entitled to complain to the Privacy Commissioners of Canada, see https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/file-a-complaint-about-a-business/file-a-complaint-under-pipeda/ for details of how to do so.
Timeframe for response
We will provide you with the information requested within 30 days of receipt of all information relevant to your request. To avoid any delays in processing your request, please ensure that you have provided all of the information requested below.
In the case of numerous or excessive requests, the normal 30-day response time limit may be extended for a maximum of 30 additional days, according to specific criteria set out at Subsection 8(4) of the Act to provide this information, in which case we will inform you of this fact, and the reason that the extension is necessary.
There is no charge to you unless your request is manifestly unfounded or excessive, in which case we are entitled to charge you an administrative fee based on the cost of providing the information to you. If we consider this to be the case, we will inform you of this fact and wait for your agreement before proceeding.
Before we provide you with this information, we have a duty to verify that you are the person who this request relates to. In order to do this, we need you to provide proof of identity, this can be in the form of:
- Driving License
- Utility Bill
This information will be stored securely and held for a maximum of 10 years.
Please note that you cannot request copies of personal information which related to another person, including calls made by somebody else.
Please provide a copy of this form and proof of identity to: [email protected] or ThruFlow Marketing, 700 Gillard Street, Wallaceburg, Ontario, CANADA N8A 4L3.