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Our Commitment to Privacy

Douglas Window & Door Inc. (“DWD”, “it”, “us” or “we”) is committed to protecting the privacy and confidentiality of personal information in its possession.

This privacy policy is available from our website (“https://www.douglaswindowanddoor.com”) and it explains how personal information is collected, used and disclosed concerning DWD’s customers and other individuals. DWD is committed to collecting, using and disclosing personal information responsibly and in accordance with this privacy policy.

If you do not consent to the collection, use and disclosure of your personal information in accordance with this privacy policy, do not provide DWD with any personal information. It is important to note that some sections of this Website can only be used, and some of DWD’s products and services can only be provided, if DWD receives the appropriate and required personal information. Consequently, should you choose not to provide DWD with the required personal information, DWD may be unable to offer access to this Website, or products and services, to you.

DWD does not knowingly or intentionally collect personal information from visitors who are under the age of thirteen (13). By using this Website or receiving any products of services from us, you represent and warrant that you are over the age of 18 and are lawfully able to accept this Agreement. If you do not have the capacity to enter into a legal agreement in the province, state, territory or country in which you reside, do not access or use the Website or receive any products or services from us unless your parent or guardian enters into this Agreement on your behalf and consents to your access to and use of the Website and any products or services we provide to you.

Accountability: DWD has designated a Privacy Officer who is responsible for the creation, oversight and implementation of this Privacy Policy and procedures to protect personal information, for receiving your privacy-related questions, and for providing you with information about our privacy practices. Our Privacy Officer is also responsible for notifying you of any material changes to our privacy practices, by posting updated information on our Site.

You can contact our Privacy Officer:

Name: Christopher George
Email: chris@douglaswd.com
Phone: 519-850-9170
Attention: Privacy Officer

Please contact our Privacy Officer to obtain further information about DWD’s policies and procedures, to seek access to personal information DWD may have about you, or if you have any unresolved inquiries or concerns. DWD will respond to you and try to resolve your concerns. DWD may need to ask you for personal information to verify your identity.

Personal Information: For the purposes of this privacy policy, the term “personal information” means any information that is defined to be personal information under applicable privacy laws. Usually, this refers to any information about an identifiable individual or any information that can be used to identify an individual. As an example, personal information may include any of the following: a person’s name, email address, residential address, telephone number, social media addresses, and in some cases, more sensitive information such as but not limited to gender, demographic information, family status, investment particulars, consumption preferences, business expenditures, credit score, accounting data, social security or social insurance numbers, bank account information, and payment card information.

In most circumstances, personal information does not include the business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information, such as information in a public directory, is not personal information under this privacy policy.

Purposes: DWD may collect, use or disclose personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:

To provide communications, and deliver programs and event information;

To establish, maintain and manage our relationships with users of the Website;

To provide products and/or services to users and/or access to DWD’s Website;

To comply with DWD’s legal obligations and regulatory requirements;

To provide information to anyone working with or for DWD as needed for the provision of DWD’s products and/or services;

To develop and manage DWD’s business and operations;

For billing, accounting and debt collection services relating to DWD’s products and services;

To distribute publications, invitations, advertising, and other communications that DWD believes may be of interest to DWD’s clients, customers and other individuals;

To respond to questions and concerns of users;

To contact users for survey or client satisfaction purposes, or for the purpose of market or other types of research;

To detect and protect DWD and third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with DWD’s insurers;

To otherwise communicate with DWD’s insurers;

To generate analytics, improve system design, create benchmarks and conduct trending analyses;

To comply with any laws, regulation, court orders, subpoenas or other legal process or investigation and to protect ourselves and other individuals from harm;

To support hosting and backend infrastructures of DWD or of third parties that assist DWD;

To generate location-based interactions;

To manage contacts and to manage the sending of messages;

To undertake registration and authentication of users;

To monitor system usage, server and software performance;

To assist you with technical support issues – it is important to note that most technical issues can be resolved without a DWD customer service representative viewing your personal information;

To assist in due diligence relating to any corporate action such as a financing, merger, amalgamation, sale or divestiture, provided that reasonable safeguards are taken to protect the confidentiality of personal information in our possession;.

For internal, external and regulatory audit purposes; and

For any other purpose for which DWD has your consent.

Limiting Collection: DWD collects your personal information in accordance with this privacy policy. DWD will try to limit the collection of your personal information to only the minimum amount of personal information required to fulfill the identified purposes, such as facilitating use of this Website, and provision of any products or services to you. However, in some instances we may provide you with the option of sharing additional personal information that will enhance your use of our Website and any products or services we provide to you.

Limiting Use, Disclosure and Retention: DWD and its staff will use your personal information in accordance with this privacy policy. DWD will not use or disclose personal information for purposes other than the purposes identified herein, or for purposes for which we have obtained your consent elsewhere.

We also ensure that only our employees, or third parties, responsible for the Website operations, or for providing you with any products or services, have physical or technical access to personal information and only where such access is required to perform work authorized by us.

DWD will retain personal information only for the duration of your enrolment as a DWD user unless otherwise required by our obligations to you, to third parties, or by law. Personal information will be retained in fully encrypted, secure and segregated databases. If you choose to withdraw from the Services, we will securely destroy your personal information in our possession and control within a reasonable period of time, unless we are required to retain such personal information longer to fulfill our obligations to you, to third parties, or by law. However, we may retain non-personally identifiable information indefinitely.

We retain all personal information provided by you on secure servers in Canada or in jurisdictions outside of Canada. Some of our third party partners and service providers may store data received from you (including personal information) on servers in Canada or in other jurisdictions outside of Canada. Data, including personal information, stored outside of Canada will be subject to the laws of the jurisdiction in which such data is stored.

By accessing our Website you consent to the storage of your personal information in Canada or outside of Canada and recognize that if your personal information will be subject to the laws of the jurisdiction in which such data is stored. This consent includes all personal information provided via the Website including any password protected portion of the Website.

If access to our Website or use of any of our products or services are provided to you by one of our third party service providers, the third party service provider may have their own terms of use and privacy policies that will govern your relationship with such third parties. You are responsible for reviewing and agreeing to these terms of use and policies. If you do not agree with these terms of use or privacy policies you should not use the products or services offered by such third party service providers.

When DWD data is viewed via a mobile device, some data is cached in the memory of the device. That data is deleted when the related application is closed and does not persist. If the application is put in the background without closing, the data may remain in the cache. We take no responsibility for any unauthorized viewing of this data by third parties.

When possible, DWD will use non-identifiable, aggregate information (e.g. number of users and transactions) when providing information to any third party.

Consent: DWD takes a consent-based approach to the collection, use and disclosure of personal information. We collect personal information directly from you and may collect personal information about you from other sources, such as websites having links to or from this Website, government ministries, departments or agencies, government registries, investigators, health institutions or organizations, insurance companies or financial institutions. We will only obtain personal information from such organizations (e.g., your bank or other third party service providers) when you provide us with the account numbers, passwords or other credentials required to retrieve the personal information, for the purpose of providing you with use of our Website or use of products or services we provide to you.

We use and disclose the personal information only as described in this policy, in accordance with other consents we receive from you, and in accordance with our Terms of Use.

Privacy legislation requires DWD to obtain the consent of an individual to the collection, use or disclosure of personal information in many circumstances.

By providing your personal information to DWD, you agree that DWD may collect, use and disclose your personal information in accordance with this privacy policy and as otherwise permitted or required by law, and that DWD may access, process and store your personal information in Canada or another jurisdiction.

When DWD receives personal information from you for the purposes of providing you with use of this Website, DWD’s products or services, or for other uses identified herein by DWD, you are providing DWD with consent as follows:

1. to allow DWD to deal with that personal information in a reasonable manner;

2. to allow DWD to provide your personal information to third parties it engages to provide or support DWD’s Website, or to provide any products or services to you;

3. to allow DWD to collect your additional personal information from third party sources when you provide us with information required to retrieve your information from such third party sources;

4. to allow DWD to use and store your personal information for the purpose of providing you with the products and services you purchase from DWD and to utilize this Website; and

5. to allow DWD to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your personal information by DWD.

If you need to provide DWD with personal information about other individuals, including but not limited to any of your employees, agents, contractors or representatives, you represent and warrant to DWD that:

• where required by law and prior to your disclosure to DWD, you will obtain the consent of each individual to the collection, use and disclosure by DWD for the specific purpose(s) that the disclosure is made by you; and

• you only collect, use and disclose personal information of each individual in compliance with applicable privacy laws.

Providing DWD with your personal information or the personal information of other individuals is always your choice. When you use this Website, request products and/or services from DWD, utilize DWD’s services, or register with this Website, DWD asks that you provide information that enables DWD to respond to your request and/or provide you with DWD’s products or services. In doing so, you consent to DWD’s collection, use and disclosure to appropriate third parties of such personal information for these purposes.

There are legal exceptions where DWD will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if DWD must comply with a court order or governmental order.

If DWD sells its business or merges with another party, your consent will be implied to transfer your information to DWD’s successor for the same purposes as set out in this privacy policy.

Disclosure of personal information: DWD will only disclose your personal information for the purposes set out in this privacy policy.

DWD will never sell your contact details to a third party. DWD does not sell client lists or personal information to others. In providing DWD’s products or services or access to DWD’s Website, DWD may need to disclose the personal information DWD collects to other service providers or agents who perform various functions for DWD, provided such suppliers agree to keep all personal information private, confidential and secure and to use the personal information only to carry out work on DWD’s behalf.

In certain circumstances, DWD may be required to provide personal information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstance DWD may have a legal duty or right to disclose personal information without the individual’s knowledge or consent. Various government agencies such as the Canada Revenue Agency, Human Rights Commission, Ontario Ministry of Finance; Ontario Ministry of Labour, etc. and law enforcement, have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.

Privacy and Our Websites: Each time a visitor comes to the Website, DWD’s web server may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities on DWD’s Website and/or webpages linked thereto. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. DWD may use this non-personal information to optimize DWD’s Website, products and/or services.

DWD may, from time to time, use “cookies” solely for security and authentication purposes. Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or services. At your option, you may turn off DWD’s “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of DWD’s Websites, products and/or services. To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser.

DWD may, from time to time, engage third parties to assist with this Website, and such third parties may track your usage, locate your geographic position, collect personal information, send messages to you on behalf of DWD, push notifications to you, and use “cookies”, as discussed herein.

By accessing and browsing DWD’s Website, products and/or service(s), you agree that DWD, or any third party it engages or that assists DWD, may collect, use and disclose any information collected about you through DWD’s Website, products and/or services or that you provide to DWD through DWD’s Website, products and/or services as described in this privacy policy.

DWD’s Website, products and/or service(s) may contain links to other sites and may provide forms on behalf of other organizations. This privacy policy only applies to personal information that we collect, use and disclose. DWD is not responsible or liable for the privacy practices of third parties, including any organizations on the behalf of which DWD provides forms, and DWD strongly recommend that you review a third party’s privacy policy before disclosing any personal information to the third party.

Retention and Destruction of personal information: The amount of time DWD will retain personal information varies, depending on the use of this Website, the products or services DWD has provided, and the nature of the personal information that DWD holds. DWD retains personal information for such period of time as is necessary for DWD to maintain sufficient information so DWD may respond to any issues that arise at a later date or as is required by law.

When personal information is no longer required by DWD or by law, DWD will either convert it into an aggregated non-identifying form or DWD will appropriately destroy or erase the personal information in a manner that is in accordance with DWD’s current policies and procedures.

If you are a member and at any point you decide that you no longer wish to participate as an DWD member, your practice information record required for the Website will be deleted and a copy of such record will be stored offline in a secure archive in accordance with related laws. Should you reinstate your membership information from this record may be accessed and utilized by DWD.

Safeguards: DWD implements reasonable industry practices appropriate to the sensitivity of your personal information to protect DWD’s systems and personal information under DWD’s control against unauthorized access and use. We use administrative, technical, and physical safeguards to protect your personal information against loss, theft, and unauthorized access, use, disclosure, copying, modification, disposal, or destruction in accordance with applicable legal requirements and industry best practices.

For example, we implement encryption and security controls to protect against unauthorized access to personal information during electronic transmission, and we train our employees to follow privacy and security practices specific to the Services. We also undertake security assessments to ensure that we maintain strong security controls.

DWD may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and DWD does not have any control over such external servers or services.

Electronic Communications: Email is frequently DWD’s preferred method of communicating with you and others, and, unless you object, DWD may use unencrypted plain text or html-based emails or messages when communicating with you. These emails or messages, and other electronic means by which DWD may communicate with you, may contain information that is confidential, unless you instruct DWD not to send such information electronically. DWD may communicate with you through other electronic means, in accordance with the contact information you provide to DWD.

While DWD makes every effort to secure all electronic communications within DWD’s control, there are inherent risks involved with exchanging information electronically. For example, such information may be accidentally or deliberately intercepted by third parties. DWD is unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.

DWD will endeavour to be compliant with Canada’s Anti-Spam laws (“CASL”) in DWD’s commercial electronic communication with you. Should you fail to provide DWD with the requisite consent to send you commercial electronic messages, or withdraw such consent, DWD may be unable to provide, or continue to provide, this Website or some of DWD’s products and/or services that can only be provided if DWD receives appropriate and required personal information. CASL consent can be provided or withdrawn at: info@douglaswd.com.

An unsubscribe link will also be provided in our emails to you.

Keeping Information Accurate/Access and Correction: DWD relies on you to ensure that the personal information you provide to us while using the Website or any products or services that we provide to, relating to yourself or any other individual, is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You must verify all information created from your use of the Services and we recommend that you consult an accounting professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk.

You are responsible for ensuring that that the information you have provided is truthful, accurate, reliable and complete.

It is important to DWD that your personal information held by DWD is accurate and complete. Having accurate information about you enables DWD to give you better service. It also helps to ensure the accuracy of the information in our reports, displays, articles and support queries, you can help DWD keep personal information up-to-date by keeping DWD informed of any changes, such as a change of address, telephone number or any other circumstances.

With some exceptions, DWD has the right to access, verify and amend the information DWD has about you after DWD has received your written request and authenticated your identity.

In some situations, DWD may not be able to provide access to certain personal information as the right to access personal information is not absolute. If DWD does not provide you with the requested information, DWD will notify you in writing and explain DWD’s reason(s) for not fulfilling your request.

Despite DWD’s efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let DWD know and DWD will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from DWD. DWD will note errors, incomplete information or unresolved differences in information collected in any file it has relating to you.

You agree to indemnify and hold DWD, its affiliates, subsidiaries, partners, service providers, suppliers and contractors and each of their respective officers, directors, agents, and employees, harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from the collection, use and disclosure of personal information relating to you or any individual that you provide to us, and any personal information relating to you that we obtain from third party sources in accordance with this privacy policy.

Withdrawal of Consent: At any time and without penalty, you can withdraw their consent to DWD’s collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions, by emailing us at info@douglaswd.com.

Should you choose to withdraw your consent, DWD may be unable to provide, or continue to provide, this Website or some of DWD’s products and/or services that can only be provided if DWD receives appropriate and required personal information. Consequently, should you choose not to provide DWD with the required personal information, DWD may be unable to offer this Website and such products and/or services to you.

You may, at any time, ask DWD not to send you further marketing materials about DWD’s products or services or if you do not wish to receive further invitations, you may unsubscribe or ask DWD not to contact you for these purposes.

You can also request that we close your account at any time, subject to reasonable notice and any legal and/or contractual restrictions, by emailing us at: info@douglaswd.com.

Once your account is closed, all personal information relating to your account will be deleted from our databases. However, anonymous transactional data (which does not personally identify you or any of your employees, agents, contractors and representatives) will be retained in our database.

Withdrawing your consent will not prohibit DWD from undertaking actions that DWD has already taken based on your prior consent.

Openness: DWD makes clear and transparent notice of its privacy practices, and this privacy policy is publicly available on our Website. This privacy policy describes the collection, use, disclosure, and protection of personal information and provides the contact information of our privacy officer.

DWD will advise you at the first reasonable opportunity upon discovering or being advised of an incident whereby your personal information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by unauthorized persons or in an unauthorized manner.

Privacy Concerns: DWD will respond to questions and concerns relating to DWD’s personal information handling practices and this policy. Please direct such questions and concerns to our privacy officer with the following indication on the envelope, on the letter and/or in the email, as applicable – Attention: Privacy Officer

Individual Access: Upon request, we will inform you if we hold any personal information about you and provide you with access to this information, within a reasonable period of time, and as permitted in accordance with applicable laws. If we have any personal information about you, we will also tell you for what purposes it is used or disclosed, within a reasonable period of time, and as permitted in accordance with applicable laws.

You have a right to update any personal information that we hold about you. Should you wish to see the full contents of your personal information file, you must make a formal written request and mail it to our privacy officer with the following indication on the envelope and the letter – Attention: Privacy Officer. We will respond to you within a reasonable period of time, or let you know why there might be a delay.

Changes to this Privacy Policy: This privacy policy is effective as of February 1, 2018. DWD reserves the right to change this privacy policy, and any of DWD’s policies and procedures concerning DWD’s practices for handling personal information, at any time and without any prior notice. If DWD has modified or amended our privacy policy, DWD will post the most current version on DWD’s Website. Any changes that are made to this privacy policy will apply to both any personal information that DWD holds prior to the effective date of the amended privacy policy and any personal information that DWD collects on or after such effective date.

Successors and Assigns: DWD’s successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this privacy policy.

© Douglas Window & Door Inc., 2018.

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