The purpose of this Policy is to inform you of the measures we take to protect your personal information and the ways in which we collect, use, disclose and retain member information in order to operate the Program. “Personal information” is any information that can identify an individual or information about an identifiable individual, such as a member's address, telephone number, or a member's transaction activity. (This Policy does not apply to aggregate information, which does not include name, contact information, or any other information that would allow a particular individual to be identified.)
- What personal information we collect
- How we collect it
- How we use that information
- How to opt-out of promotional and marketing offers
- How we may share personal information
- How we protect your information
- How to access, verify and update your information
- How to reach us should you have any questions or concerns
When you become a Member of the Program, or any time that you interact or do business with us, you agree to the terms of this Policy as updated from time to time. Whether you are new to the Program or a long-time member, please take the time to get to know and familiarize yourself with our privacy policies and practices as described in this Policy. We are constantly reviewing our policies and practices, taking into account changes to privacy laws and feedback from members. Amendments to this Policy will be posted on our website and we will take reasonable steps to communicate any material changes to members.
We will only use and disclose your personal information to fulfill the purposes for which it was collected or as otherwise identified in this Policy. Other uses of your personal information will only be undertaken after we have obtained your additional consent, or as may be required or permitted by law.
What personal information do we collect?
We collect personal information in order to manage the Program and allow for points accumulation and redemption. The following are examples of personal information that we collect:
- When you enroll in the Program, we collect identifying information, such as your name, mailing address, telephone number, and email address.
- When you visit our website, we may collect information about your usage such as the webpages viewed, frequency of visits, time spent on the site, and location information.
Whenever you make qualifying purchases, information may be transferred to the Program, such as:
- your membership number;
- a description of the transaction for which the points were earned; and
- the number of points earned.
How do we collect personal information?
We rely on you to update your profile as required and ensure that your contact information is accurate. On occasion, we may acquire additional data from trusted third parties who have the necessary consent to provide such information, in order to help us better administer our program and understand your interests and preferences. Generally, the information received from third parties is used to help us update, expand and analyze our records and may be used identify new customers.
How do we use your personal information?
We use your personal information to administer the Wolseley PRO Rewards program and enhance your experience as a member of the Program. This includes the management of member accounts to accurately record and update the points that you have accumulated through qualifying purchases or that you have redeemed. We also use your personal information to better understand your preferences, needs, interests and usage in order to develop, enhance, and provide products and services that best meet your expectations, and to measure the success of the Program’s features, benefits and promotions.
In particular, we may collect, use and disclose your personal information for a number of purposes, including:
- To contact and communicate with you;
- To verify your identity;
- To advise you of changes to the Program;
- To provide customer service, respond to and process redemption requests and address questions you may have about your account;
- To communicate offers about accumulation and redemption opportunities, benefits, products and services provided by Wolseley; and
- For quality assurance and record keeping purposes.
We will not collect, use or disclose personal information for other purposes without obtaining your further consent, except where authorized or required by law.
How to opt-out?
The Wolseley PRO Rewards Program respects the privacy of its members when promoting products or services. You may withdraw your consent to uses of your information that are beyond what is necessary for the administration of the Program. If you no longer wish to receive marketing and promotional offers, you may withdraw your consent by by clicking on the “unsubscribe” link in our email communications to you. You may also log into your Member account online and change your preferences.
Members can also opt out of receiving marketing and promotional communications in electronic, printed or verbal format by writing us at:
Wolseley PRO Rewards Program
PO Box 73564
Toronto, ON M6C 4A7
By email to firstname.lastname@example.org
The decision to opt out of additional marketing and promotional communications does not affect a Member’s ability to collect or redeem Wolseley PRO Points in the Wolseley PRO Rewards Program. We may however, still use your email address to provide information about your membership in the Program or your account.
How do we share your personal information?
We recognize your concerns about the security of the personal information that you provide to us. As a general rule, we do not sell or otherwise share personal information about you with outside parties. Your information will not be sold, exchanged or transferred to any other company for any reason, other than for the express purpose of administering the Program and delivering products or services to Members. To this end, your personal information will be transferred from Wolseley Canada Inc. to Lift & Shift and vice versa, in order to administer the Program.
We share your personal information in order to administer your account, develop and promote the program, and make offers related to accumulation and redemption opportunities, benefits, products and services. The Wolseley PRO Rewards Program may temporarily share information with a Partner in order to increase opportunities for members to accumulate Points, to facilitate the redemption of rewards, or to obtain special benefits for members. In these circumstances, use by the Partner for a purpose unrelated to the Program is strictly prohibited.
Your personal information may be transferred to third-party service providers, including data processing and storage firms, that perform work or provide services in order to help us to manage and administer the Program. These service providers are contractually obligated to maintain confidentiality, safeguard all information provided to them, and use the information disclosed to them only for the purposes of the Program.
We may be required to disclose information about you:
- if required to do so by law, regulation or legal process (such as a court order or subpoena),
- in response to requests by government agencies, such as law enforcement authorities, or
- when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
- We reserve the right to transfer any information we have about you in the event of a sale or transfer of all or a portion of the business or assets (including in the event of a reorganization, dissolution or liquidation) of either Wolseley Canada Inc. or Lift & Shift Inc.
How do we protect your information?
We have implemented processes and procedures to keep your personal information safe and secure have put appropriate safeguards (physical, technological and organizational) in place. Employees are trained on the importance of maintaining the security and confidentiality of personal information. Please note that while we use reasonable efforts to protect your personal information, we cannot guarantee the security of any information that is transmitted via the Internet.
Your personal information will only be collected, used and disclosed, and will only be retained as long as required to fulfill the purposes for which it was collected, or as may be required by law. Your personal information is retained in secure facilities, such as offices and data centres with restricted access. Electronic data is protected by technological means, such as firewalls, access controls and encryption.
We retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. When a member's account has been inactive for seven (7) years, all personal information is destroyed, anonymized or otherwise disposed of using secure methods.
Your personal information may be transferred to a third-party service provider who provides services to us or on our behalf such as hosting, data management and storage services. We may, or any such third-party service provider may, use servers for such purposes which are located outside of Canada. Where your personal information is processed in a location outside of Canada, the laws of any such foreign jurisdiction may apply.
How can you find out what personal information we have?
You can access, verify and update your personal information directly online, as well as review your recent transaction history by logging in to your account on our website. You may also request access to this information by writing to us or contacting our customer service centre.
You may request that updates or corrections be made to your information in order to ensure that it remains complete and accurate.
Questions or Concerns?
If you wish more information, access to your records or you if you believe that we are not complying with the privacy practices and procedures set out in this Policy, you may contact our Privacy Officer in writing at the address or email address below:
PO Box 73564
Toronto, ON M6C 4A7
The Privacy Officer or designate receives all inquiries and complaints and will ensure that a response is provided in a timely manner. If your inquiry or complaint cannot be resolved immediately and requires further investigation, we will advise you that your inquiry or complaint is being reviewed and when you can expect an answer.
In the event that we have responded to your inquiry or complaint, but you feel that your concerns have not been resolved, you will be advised to contact the office of the Privacy Commissioner of Canada, or if applicable, the Provincial Privacy Commissioner. Our Privacy Officer will provide this contact information to you on request.
This Policy was last modified on January 18, 2019.