Updated September 10th, 2018Introduction:
Liquor Depot, including its affiliates of SNDL INC. is committed to safeguarding the personal information entrusted to us by our customers. We manage your personal information in accordance with Alberta’s Personal Information Protection Act (PIPA) and other applicable laws. Our Personal Information Protection Policy outlines the principles and practices Liquor Depot follows in protecting our customers’ personal information. The policy also applies to any person providing services on our behalf. A copy of this policy is available on our website http://wineandbeyond.ca and a copy is available via email at Privacy@sndl.com.
Personal information means information about an identifiable individual. This includes an individual’s name, home address and home or cellular phone number, email address or web information, age, sex, marital or family status, identifying number, financial information, educational history, photograph, video, etc.
The Personal Information that We Collect:
We collect and maintain different types of personal information in respect of the individuals with whom we interact, including via our Sites and mobile applications ("Apps"). This includes:
- contact and identification information, such as your name, address, telephone number, e-mail address, date of birth, user ID and password;
- billing and shipping address;
- payment information (e.g. credit card);
- product and service related information concerning the products and services that we provide to, or receive from, you; and
- any other information described in this policy.
In general, we collect only the personal information that we reasonably require for the purposes of providing certain services to our customers, including personal information needed to:
Sell products and services in store or over our Sites or Apps using credit cards, debit cards, and other financial mechanisms requiring personal information be revealed;
Send out marketing and promotional information;
Contact customers about specials of products;
Follow up with customers to determine satisfaction with products and services and provide customer service or other support associated with such products and services;
To open and manage an account on our Apps and to provide services with respect to such accounts;
Notify customers of upcoming events of interest;
Meet regulatory requirements;
Enable us to comply with your requests; and
Protect the safety and security of customers within our stores.
We inform our customers, before or at the time of collecting personal information, of the purposes for which we are collecting the information. However, we do not provide this notification when a customer volunteers information for an obvious purpose (for example, producing a credit card for an in-store purchase or purchase through our Sites or Apps when the information will be used only to process the payment).
Consent in our Personal Information Protection Policy:
We ask for consent to collect, use or disclose customers’ personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume consent in cases where a customer volunteers information for an obvious purpose (such as for marketing purposes).
We ask for a customer’s express consent for some purposes and may not be able to provide certain services if customers are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask customers to provide their consent orally or in writing, depending on the nature of the issue being consented to.
A customer may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfill our legal obligations. We will respect your decision, but we may not be able to provide you with certain services if we do not have the necessary personal information.
We may collect, use or disclose customers’ personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.
Use and Disclosure of Personal Information:
We use and disclose customer’s personal information only for the purposes for which the information was collected, except as authorized by law as discussed above. If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.
We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. Some of our operations, such as advertising and promotions, may be managed and run by our Canadian and US service providers ("Service Providers"). As a result, your personal information may be collected, used, processed, stored or disclosed in the United States and may potentially be accessible to law enforcement and national security authorities of that jurisdiction. These Service Providers may have access to your personal information on a confidential basis to the extent necessary to perform their functions. In no event will these companies have the right to use your personal information for any reason other than to provide you or us with those specific services, except as may be permitted by law. Information provided by you will be used by SNDL INC. and its Service Providers to learn about the experiences of our customers so that we may enhance our programs and improve our level of service. For further information on the manner in which our service providers process your personal information, please contact our Privacy Officer at the contact information below.
In addition to the above, personal information may be disclosed or transferred to another party during the course of the grant of a security interest in Liquor Depot's assets, or the completion of a sale of all or a part of Liquor Depot through, for example, an asset or share sale, or some other form of business combination, merger or joint venture; provided, however, that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this policy, unless you consent otherwise.
IP Addresses, Cookies, Tracer Tags and Third party Links:
In general, you can visit our SNDL INC. websites ("Sites") without telling us who you are or providing us with any information. However, we may collect the IP (Internet protocol) addresses of all users of our Apps or visitors to our Sites and other related information such as page requests, browser type, operating system and average time spent on our Apps or Sites. We use this information to monitor and improve our Apps and Sites.
SNDL INC. and our Service Providers use various technologies to collect and store information when you visit our Sites or use one of our Apps or services. This may include sending one or more cookies, java scripts, web beacons or anonymous identifiers to your device ("cookies"). A cookie is a small text file that our Sites can place on your computer’s hard drive. Using cookies we may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. We may also collect information on your use of our Sites such as the time that the current visit occurred, whether the visitor has been to the site before, what site referred the visitor to the web page and your usage patterns on our Sites including the time you spend on our Sites and which parts of our Sites you are visiting. This is statistical data about our users’ browsing actions and patterns. We do not collect personally identifiable information about you, including your name, address, phone number or email address using cookies. To the extent that you provide us with personally identifiable information, whether by creating a user account on our Sites or through our Apps, or ordering products or services, this data is kept separate from and not merged with the data automatically collected by cookies.
Cookies are used to improve your experience on our Sites (e.g. to maintain a shopping cart or remembering your details and preferences when you return). We use this information to improve our Sites and to improve the user’s experience when using our Sites. You can set your web browser to block cookies, but doing so may affect your ability to access certain features of our Sites.
We may share aggregate data collected by cookies with our Service Providers, suppliers and other third parties, however, we do not share personally identifiable information (such as name, address, email or phone) with third parties, except as permitted by law.
We do not knowingly collect personal information from minors under the age of 18. If you believe we have inadvertently collected such information, please contact us immediately so we can obtain parental consent or remove the information.
Our Sites may also use Google Analytics which is a web analytics tool utilizing first-party cookies to track visitor interactions with our Sites. Google Analytics customers can view a variety of reports about how visitors interact with their website that helps website owners better engage its visitors and improve its website. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can also opt out of Google Analytics without affecting how you visit our Sites – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page https://tools.google.com/dlpage/gaoptout. Our Sites may also use a technology called "tracer tags". These may also be referred to as "Clear GIFs" or "Web Beacons". This technology allows us to understand which pages you visit on our Sites. These tracer tags are used to help us optimize and tailor our Sites for you and other future.
Our Sites or Apps may include links to the websites of our business partners, vendors and advertisers. Except as provided herein, we will not provide any of your personal information to these third parties without your prior consent.
SNDL INC. provides links to third party websites as a convenience to the user. The inclusion of any link does not imply SNDL INC.’s’ endorsement of any other company, its websites, or its products and/or services. These linked websites have separate and independent privacy policies, which we recommend you read carefully. We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose and otherwise treat your personal information.
Updating Personal Information:
We make every reasonable effort to ensure that customer information is accurate and complete. We rely on our customers to notify us if there is a change to their personal information that may affect their relationship with our organization. If customers are aware of an error in our information about them, we request that they please notify us and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
Safeguarding Personal Information:
We protect customer personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. For example, we have employees sign confidentiality agreements to protect customer information and use up-to-date technological protections such as firewalls and passwords.
We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.
We retain customer personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.
We render customer personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying customer personal information, including shredding paper records and permanently deleting electronic records.
Access to Records Containing Personal Information:
Customers of Liquor Depot have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, under PIPA, organizations are required to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under PIPA to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
Making A Request for Personal Information:
You may make a request for access to your personal information by writing to our Privacy Officer, at Suite 101, 17220 Stony Plain Road, Edmonton, Alberta, T5S 1K6, or email Privacy@sndl.com. Our Privacy Officer is designated to ensure compliance with PIPA. You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization.
You may also request a correction of an error or omission in your personal information.
We will respond to your request within 45 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.
Questions or Concerns:
If you have a question or concern about any collection, use or disclosure of personal information by Liquor Depot or about a request for access to your own personal information, please contact
Privacy Officer at:
c/o SNDL INC.
101, 17220 Stony Plain Road
Edmonton, AB T5S 1K6
If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Alberta, at:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 - 6 Avenue, SW
Calgary, Alberta T2P 3W2