KAWARTHA PREMIUM ALCOHOLS INC.

DRAFT PRIVACY POLICY

This Privacy Policy (“Policy”) describes how and when Kawartha Premium Alcohols Inc. collect, use, and share personally identifiable information (“Personal Data”).  Personal Data will also include similar information pertaining to an identifiable juridical person or legal entity to the extent required by applicable local privacy laws.

We are committed to protecting the privacy and security of the personal information of individuals with whom we interact in accordance with applicable privacy legislation. Respecting and protecting your privacy is important to us and a priority in our continuing relationship.

What Personal Data Do We Collect?

We collect Personal Data to operate effectively and provide you with the best services and user experiences we can, but collect only the amount necessary to provide those services.  Personal information is any information about an identifiable individual or that permits an individual to be identified, but does not, in most circumstances, include business contact information. In particular we collect:

Website Information

When you access our website, we collect the internet protocol (IP) address, domain, browser, the country you are accessing from, device, return visits, referring and exit pages, pages visited, time on pages, preferences, location, clicks, and website usage, such as your browser type and version, time zone setting, and operating system and platform. We may also collect the pages you accessed on our website, the links you clicked, forwarded or clicked through. We use this information to make our website better for you and to help in spam detection.

When you use the “contact us” portion of the Kawartha Premium Alcohols’ Website, we collect the personal information that you submit such as your name, address, title and any other contact information that you provide.

Our websites have links to other sites or services not provided by us. These websites may have different privacy practices and policies than ours and we recommend that you review their privacy policies to determine if they are acceptable to you.

CCTV Footage

In the course of conducting our business, we may monitor our facilities with surveillance cameras.  If accessing our manufacturing facilities and premises, we may process footage of you obtained through our use of CCTV surveillance systems, in accordance with applicable law.

Information Collected on Social Media Accounts

When interacting with your social media accounts, we may collect your email address, Twitter handle, contact information displayed on your Facebook profile, etc.

Visitor Information

When accessing our premises and buildings, we collect your name, contact details, vehicle plate number, identification, etc. for security purposes.

Information for Recruitment

When applying for employment we collect your résumé (application) and other relevant information for recruitment purposes.  We may also ask you to perform psychometric tests as part of the recruitment process and collect information about aspects of your personality that are relevant to the workplace. If your résumé is incomplete, we may ask you to provide us with further information about your educational and employment background, address, contact details, certifications, driver license, gender, etc. We will not ask you for any information that we are not allowed to request under applicable laws.

Website Cookies and Other Technologies

Cookies and other, similar technologies are used when you visit our websites.

These technologies collect non-personal information to make your experience on our websites better. We gather this information to make our websites more efficient and relevant for you, improve website functionality and fix experiences that may be broken.

Specifically, we use:

  • Google Analytics: this program tracks how visitors use our website.
  • Cookies: these small text files are placed in the temporary folder of your browser and help us track information about the use of our website during your session and help improve your web browsing experience.
  • Session data logs: our servers automatically collect some anonymous information about your session and create log files.

You are consenting to our use of cookies and tracking technologies by visiting our website with a browser that is set to accept cookies.

To disable cookies, visit the Help menu within your browser. Each browser is different, but the menu will walk you through how to ensure your preferences are updated.  Our website works best with cookies. Your experience may not be as optimal without them.

To opt out of Google Analytics tracking, use Google Chrome to browse our sites and download their Google Analytics Opt-out extension.

Consent

We collect, use and disclose your personal information on the basis of your consent (express or implied) or as required or permitted by law. By providing us with your personal information, you consent to our collection, use and disclosure of that personal information in accordance with this statement of privacy practices. If this statement of privacy practices is not acceptable to you, please do not submit any of your personal information.

You can withdraw your consent to our collection, use or disclosure of your information at any time. Contact us at privacy@kawarthapremiumalcohols.com to request that your name be removed from our telephone, mail or email marketing lists. We will advise you of any consequences of the withdrawal of your consent, as sometimes withdrawing consent means we can no longer provide a product or service to you.

Use of Your Personal Data?

We use your Personal Data for following purposes:

  • Manage, develop and improve our business and operations, products and service offerings.
  • Understand your preferences, and product and services’ needs.
  • Manage our supplier and customer relationships and better understand their changing needs.
  • To perform market research, improve our products and services, and for the study and understanding of the business and preferences of our customers.
  • Tailor our marketing activities to customers’ needs including providing localized content based on your location.
  • Engage in a business transaction.
  • Consider your application for employment opportunities with Kawartha Premium Alcohols.
  • Prevent fraud, negligence, or other criminal activities, and to manage risk exposure.
  • To respond to your comments and questions (problem resolution)
  • To provide customer service
  • To help us prevent unauthorized individuals from accessing, changing or deleting your Personal Data.
  • To identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers.
  • To maintain a safe and secure environment for our people, visitors, products, and processes.
  • To contact you via your social media accounts, to answer your inquiries and better engage with our customers.
  • To protect against and prevent fraud, or other criminal activities, unauthorized transactions, claims and other liabilities, and to manage risk exposure
  • To comply with building safety obligations, to identify the people that are entering our premises, and to support active pharmaceutical ingredients supplier and food safety obligations.

We will not use Personal Data for any purposes that are incompatible with those outlined in this Policy, unless you give us your free and informed consent for additional specific purposes.

Why Do We Collect Personal Information?

Monitoring of our Facilities and Equipment

­­­­­­­­­To Whom Do We Disclose Personal Data?

We do not sell or lease your Personal Data to others. We only share Personal Data with third parties who are bound by terms at least as restrictive as this Policy and only in the following ways:

Affiliates – We may share Personal Data with any of our affiliates or subsidiaries, for example, for the purpose of providing customer service, and improving our products and services. We may also share your Personal Data with affiliates or subsidiaries that provide shared services to Kawartha Premium Alcohols, for example, in connection with the purchase and sale of products, financial and accounting support, recordkeeping, customer billing and collections, order processing, credit control, accounts payable processing, and preparing and reporting estimates and results.

Service Providers – We share Personal Data with third party providers of services relating to, i.e. our website, the provision of our customer service, our CCTV surveillance, our market research and sales, our recruiting, IT systems or software, IT support, document and information storage. These service providers only have access to the Personal Data necessary to perform their functions, only act on our behalf and under our instructions, and may not use it for purposes other than to perform such services.

Legal – We may disclose Personal Data to courts, law enforcement agencies, and other government bodies where we believe that doing so is in accordance with or required by any applicable law, regulation or legal process.

Third Party Data Service Providers – we may share Personal Data with third party data service providers who help us to segment and understand our customers by providing additional information so that we can send you what we believe will be the most relevant, targeted, and beneficial product offers and advertisements.

Third-party providers use the information only for the purposes for which it was disclosed, and agree to maintain privacy policies consistent with those of Kawartha Premium Alcohols Inc.

External Links

This Policy does not apply to the collection, processing, and use of Personal Data by companies that we do not own or control, or to people that we do not employ or manage (“External Parties”). Although some of our websites may link to the websites and services of External Parties, such as those of our business partners and social media companies, we do not exercise control over the activities of External Parties. For more information about what Personal Data External Parties collect and how they use such Personal Data, please refer to their privacy policies.

How Do We Protect Your Personal Data?

We maintain reasonable administrative, technical and physical safeguards to protect Personal Data against loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction as required by applicable law.

Unfortunately, the transmission of information via the Internet is not completely secure. Despite our safeguards, we cannot guarantee the security of information transmitted to us via the Internet. Once we have received your information, we will maintain reasonable safeguards to protect it.

Your personal information is protected utilizing a combination of security technologies and practices such as data encryption, firewalls and security monitoring and audits.

Where is Your Personal Data Stored?

Your Personal Data may be stored and processed by us in our offices or at our service provider in Canada.

Kawartha Premium Alcohols has policies and procedures in place to ensure that we comply with all applicable laws in the event of a security incident leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Data.

General Data Protection Regulation / GDPR

If you are a resident of the European Union, this additional information applies to you:

  • The only personal information we collect about you through our website is the information you voluntarily provide when using the contact form or submitting a resume where applicable.
  • By providing your personal information, you expressly agree to this statement of privacy practices.  If this statement is not acceptable to you, please do not submit any of your personal information.
  • Any personal information you provide will be stored and utilized outside of the European Economic Area (EEA), primarily in Canada.
  • You may withdraw your consent to us using your personal information at any time (such as by clicking the unsubscribe link in an email alert that you receive).  If you withdraw consent, we will be unable to provide you with further emails or process your employment application.
  • We retain your personal information only as long as is necessary for the purposes set out in this statement of privacy practices, or as is required by applicable law, and then we will delete it.
  • Further, to the extent permitted by the laws of your country, you may also have the right to access, correct, delete, restrict, be forgotten or object to processing of, or request data portability of the personal data collected about you subject to some conditions and exceptions.
  • You also have the right to lodge a complaint with a data protection regulator.

HOW LONG WE RETAIN YOUR DATA?

Kawartha Premium Alcohols Inc. has internal retention policies and procedures that build upon the following criteria to determine the retention periods of Personal Data in the context of the above-mentioned purposes:

  • Time elapsed since your last interaction with our website
  • End of the contractual relationship with a supplier, or a third-party provider of products or services
  • Sensitivity of the Personal Data
  • Security considerations
  • Applicable statutes of limitation
  • On-going or potential litigation or dispute; and
  • Regulatory or legal obligation to retain the Personal Data (for example, for accounting purposes or in the context of CCTV surveillance).

Revisions to the Policy

We reserve the right to change this statement of privacy practices at any time by posting a new statement. Please check this page periodically for changes. Your continued use of our website following the posting of changes to the Policy means you accept those changes.

Conflicts or Inconsistencies between Policies

If there is any conflict or inconsistency between a provision of this Policy and a provision of any other policy that is referred to in this Policy, this Policy will prevail.

If you have any questions, please email us at privacy@kawarthapremiumalcohols.com