Buchanan Group Privacy Policy

Buchanan Advertising (Canada) Inc ("Buchanan Group", "Buchanan") and the other companies and organizations which make up Buchanan Group are committed to protecting the privacy of your personal information. This Privacy Policy explains how Buchanan Group manages the personal information that we collect through our website www.hometesterclub.com, any related Buchanan Group websites, social media page, internal website, intranet and any Buchanan Group mobile application (collectively "Websites") as well as how we use and disclose such personal information and how to contact us if you have any further queries about our management of your personal information.

This Privacy Policy does not cover personal information collected or held by Buchanan Group about its employees.

Background

Buchanan Group is required to comply withPersonal Information Protection and Electronic Documents Act (PIPEDA) and its ten Privacy Principles (Privacy Principles) (subject to the other provisions of that Act). PIPEDA regulates the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal. Buchanan Group is also required to comply with the Fighting Internet and Wireless Spam Act (Spam Act) and the do not call provisions of the Telecommunications Act (Telecommunications Act).

The Ten Privacy Principles:

  1. Accountability: All Buchanan Groupemployees are responsible for maintaining and protecting all personal information under their control. Buchanan Group has designated an individual to oversee the company's compliance with this Privacy Policy.
  2. Identifying Purposes: We will identify the purposes for which personal information is collected, either before or at the time of collection.
  3. Consent: We will only collect, use and disclose your personal information with your knowledge and consent, except where otherwise required or permitted by law.
  4. Limiting Collection: We will limit the collection of your personal information to only those details that are necessary for the purposes identified.
  5. Limiting Use, Disclosure and Retention: Your personal information will only be used or disclosed for the purpose for which it was collected, unless you have otherwise consented, or when it is required or permitted by law. We will only retain your personal information for the period of time required to fulfill the purposes for which it was collected.
  6. Accuracy: We will keep personal information we collect as accurate, complete and up-to-date as necessary to fulfill the purposes for which it was collected.
  7. Safeguards: We will protect the personal information we collect with security safeguards appropriate to the sensitivity of the information.
  8. Openness: Information about our policies and practices relating to the management of personal information will be made readily available to you.
  9. Access:At your request, we will inform you of the existence, use and disclosure of your Personal Information, as well as give you access to the information. You have the right to challenge the accuracy and completeness of your information, and to amend it as necessary.
  10. Challenging Compliance: You may contact us with any questions, complaints or suggestions with respect to the above principles.

What is Personal Information?

Personal information is broadly defined as information about an identifiable individual including information such as your name, address, telephone number, birth date and e-mail address. Personal information does not include the name, title, business address, or telephone number of an employee of an organization. Data we collect with personal identifiers removed, so that it is impossible to determine the identity of the person to whom the information relates, is not considered personal information.

Collection of personal information by Buchanan Group

We collect your personal information in connection with the provision of goods and services to you. The type of personal information we collect about you will depend on how you use the Website. For example, personal information is collected when you:

  • Register on a Website to become a member of the Buchanan Group community ("Member");
  • Post a comment in one of our forums;
  • submit an article, video or product review to be uploaded to this Website;
  • send a message to another Member using the direct messaging function;
  • respond to one of our product surveys;
  • enter a competition or participate in a promotion; or
  • register or subscribe for, or contribute content to, any other services available through this website from time to time.

We may also keep records of any other interactions you have with us (for example, emails or other correspondence you send via this website), together with any other information that you choose to provide to us. While we will generally collect personal information directly from you through a Website, we may also collect personal information:

  • from you over the telephone, or through written correspondence (such as letters and emails); and
  • about you from other Members (in which case, in accordance with the and this Privacy Statement, the other Member must first obtain your consent).

In some circumstances, we may collect sensitive information about you (for example, if you post a comment in a forum about your health). We will not do this unless you have consented to the collection, or if we are otherwise required or authorized to do so by or under law. Sensitive information includes (for example) health information and information about a person's racial or ethnic origin, political opinions, religious beliefs, professional or trade association membership, sexual preferences and criminal record.

If you do not provide us with the personal information that we request, we may not be able to provide you with some of our products and services (except in cases where we have indicated that the provision of that information is optional). For example, if you do not register as a Member, you will not be able to access pages of this website or other services that are reserved for Members only.

In some cases, we may obtain certain personal information from other sources. Where we collect information about you from other sources, we will take reasonable steps to ensure that the personal information is being collected with your consent and in accordance with this Privacy Policy.

Providing us with personal information about others

If, at any time, you provide personal information about another person, you warrant that you have made that person aware of this Privacy Policy and theTerms of Use and that you have obtained that person’s consent to provide their personal information to us for the purpose specified.

Cookies

A cookie is a small string of information that a website transfers to your browser for identification purposes. We may use cookies to gather information about your visits to our website and enhance your experience. The cookies used by us do not identify individual users, although they do identify the user's internet browser. We may use cookies to maintain session information about you when you log into our website and that information helps us to understand your preferences and improve your Website experience.

We may also allow third parties that publish advertisements on our Websites to place and access cookies on your computer and use the information from those cookies to tailor the advertisements that you see while browsing online with your interests.

Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. If you disable cookies, we may be not be able to optimize your visit to this website and certain features may not be available.

Use of Personal Information

Personal information will not be used without your consent for purposes other than those for which it was collected. We may collect, use and disclose your personal information:

  • to operate the Websites, including through the publication of forums, articles, videos and reviews;
  • to identify you and communicate with you generally;
  • to conduct competitions and promotions;
  • to provide you with targeted product trials;
  • to send you product samples pursuant to your membership in the Home Tester Club;
  • in accordance with the purposes set out in the including the use of personal information disclosed in any Material, as defined by the , and transferred to Buchanan Group pursuant to Buchanan Group’s perpetual license to the Material (see Public Material of Members below);
  • to obtain opinions or comments about products and services;
  • to provide customer support for Members;
  • to respond to questions and requests;
  • to tailor the advertising that is presented to you on this website and the product and service information that we may send you, for example, by providing you with product information relevant to the preferences or opinions that you have expressed on our Websites or in response to our surveys;
  • to conduct research and development;
  • to develop an understanding of your needs and eligibility for products and services to bring you offers fromBuchanan Group and its third party partners;
  • to share information collected about you and your preferences collected through cookies and other passive means including your demographic profile, browsing, usage and interactions with the Website to third parties in order to assist them with the provision of useful and relevant online advertising on our sites. This shared data will not contain user’s names, mailing addresses, phone numbers, e-mail addresses or similarly personally identifiable information;
  • to announce product safety recalls or warnings (if necessary);
  • to investigate any complaints made by or about you, or if we have reason to suspect that you are in breach of our or have been engaged in any unlawful activity; and
  • for other purposes required or authorized by or under law.

From time to time, we may wish to use your personal information for new or additional purposes. We will obtain your consent to use your personal information for such new or additional purposes before doing so unless there is a legal exception.

Your personal information may also be used to create statistics about our business. These statistics would not contain any information that could identify you personally. We may disclose and/or transfer personal information to an affiliate or third party in the event of a proposed or actual purchase, sale, merger or transfer of all or any portion of Buchanan Group or other transaction or as part of a reorganization or restructuring. We retain your Personal Information only as long as required for our reasonable business and/or legal needs.

We may disclose your personal information to third parties for the set out in this section or for the purposes that personal information was collected. Personal information may be disclosed for these purposes to:

  • the general public (both in Canada and overseas), by publication of this website on the internet
  • companies and organizations within Buchanan Group;
  • to our selected third party businesses whose products and services we think may be of interest to you (Promotional Partners); or
  • Our contracted service providers, which may include:
    • website development, information technology and security providers;
    • database management and data processing analysts;
    • creative, promotional and market research agencies;
    • mailing houses, freight and courier service providers; and
    • external business advisors (such as accountants, auditors, recruiters and lawyers).

The third parties identified above may provide us with personal information they have collected from you, for the purposes set out in this Privacy Policy. Any personal information collected from third parties will be used and disclosed in accordance with this Privacy Policy.

Product and service offers

If you are a Member, we may (unless you opt out of receiving any or all of these communications on your member profile page) use your personal information to:

  • send you news, product information and promotional offers from Buchanan Group and our Promotional Partners;
  • invite you to participate in product surveys and promotions; and
  • send you product samples and ask for your feedback.

We may send this information to you in a number of ways, including by post, email, SMS and MMS. You can let us know at any time if you no longer wish to receive these communications by updating the relevant details in your member profile page.

We do not provide directly all the products and services related to your relationship with us. With some product and service offers we may disclose your personal information to our affiliates and selected third party service providers/business partners so that they can send you promotional materials or telemarket you directly.We may use selected third party service providers/business partners to process or handle Personal Information on our behalf and to assist us with various services such as printing, mail/e-mail distribution, marketing (including telemarketing) and product/service fulfillment, and you acknowledge that we may release information about you to them. Some of our selected third party service providers/business partners are located outside of Canada. As a result, your personal information may be accessible by regulatory authorities (without notice) in accordance with the laws of other jurisdictions. For more information about our policies and practices with respect to service providers (including those located outside Canada), please contact: privacy@hometesterclub.com.

When sending product and service offers to you, we will also let you know how you may opt out of receiving such communications in future. Your consent to receiving these communications will remain current until you advise us otherwise.

Types of Consent

Unless there is an exception under law, Buchanan Group will obtain your consent for the use of your personal information. Consent can be obtained in a number of ways:

  • Consent can be express or it may be implied in appropriate circumstances.
  • Express Consent can be given by you in writing, in person, electronically, by telephone, or by using a check-off box.
  • We will not use your implied consent for the use or disclosure of your sensitive Personal Information such as financial data or for the purpose of sending commercial electronic messages.

Withdrawing Consent

Subject to reasonable notice, you may withdraw your consent at any time, unless the personal information is necessary for us to fulfill our legal requirements and similar obligations. If you withdraw your consent, we will inform you of the implications of such withdrawal. To withdraw your consent, simply contact us at privacy@hometesterclub.com and advise us of what personal information you no longer wish us to use. Personal information may be retained by Buchanan Group for reasonable purposes such as billing, audit, archival, warranty, legal/regulatory or product safety recall/warning purposes.

Public Material posted by Members

Some of the services offered through this website allow Members to submit, upload, post or transmit content or material such as text, photos, images, audio and video (including links to content or material) that may be accessed and viewed by the general public on the internet (Public Material). Members acknowledge that anything they post onto this website may appear elsewhere on the internet and may remain on the internet after their membership has ended, and accept that we cannot guarantee that the Public Material will not appear elsewhere, be copied, downloaded or used otherwise. If Members have any concerns about their personal information being published in this way, they are advised to remove any personal information from the Public Material they post, or not to use these services.

As indicated in the , we may use Public Material for any promotional purposes of Buchanan Group and our clients. This may include using Public Material which may include personal information (for example, reproducing in promotional materials testimonials which include either your personal information or a user name which identifies you), unless you opt out of this in your member profile page.

Spam

We will not send you any commercial electronic messages such as SMSs or emails unless this is permitted by the Spam Act without your express consent. Any commercial electronic message that we send will identify Buchanan Group as the sender and will include our contact details. The message will also provide an unsubscribe facility. If you do not wish to receive commercial electronic messages from us, please let us know (our contact details are provided at the end of this policy).

National Do Not Call List

We will not call you on a number listed on the National Do Not Call List unless this is permitted under the Telecommunications Act unless we have your express or inferred consent to do so. If you do not wish us to call you on a particular number, please let us know (our contact details are provided at the end of this policy).

Links to third party websites

Links to other websites are provided for your convenience. We are not responsible for the privacy practices of those sites, and you should review their privacy policies before supplying any personal information to them.

We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by Buchananor any of its affiliates. Buchananis not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.

Safeguards

We rely on the personal information we hold in conducting our business. We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up to date. You can help us by letting us know about any changes to your personal information, such as email address or phone number. Our contact details are provided under the Access and Correction section below.

With the exception of personal information contained in Public Material, we strive to protect the personal information and privacy of website users and have taken all reasonable steps to do so including:

  • storing your information on secured servers that are protected in controlled facilities;
  • physical measures including locked filing cabinets and restricting access to locations where personal information is stored; and
  • limiting access to personal information and providing training employees on the importance of safeguarding personal information from loss and unauthorized access.

The storage of your personal information on secured servers may be provided by our selected data storage providers.In some cases these facilities may be overseas, including in Australia, Indonesia, the United Kingdom and the United States of America. If you are concerned about sending your information over the internet, you can contact us by telephone or post (our details are provided under the Access and Correction section below).

You can also help to protect the privacy of your personal information by keeping passwords secret and by ensuring that you log out of the site when you have finished using it. In addition, if you suspect any security breach, please let us know immediately.

We will only retain your personal information for the period of time required to fulfill the purposes for which it was collected. When your personal information is no longer required to fulfill the identified purposes, it shall be destroyed, erased or made anonymous.

Anonymity

Buchanan Group will generally provide individuals with the option of not identifying themselves when entering into transactions when it is lawful and practicable to do so. However, personal information obtained by Buchanan Group during anonymous transactions may be retained by Buchanan Group for the purposes described in this Privacy Policy.

Access and correction

Please contact us if you would like to access or correct the personal information that we hold about you. Buchanan Group may require sufficient information about an in order to provide sufficient information to permit an organization to provide an account of the existence, use, and disclosure of personal information. This information will be used for this purpose only.

We will generally provide access or make corrections, subject to some exceptions permitted by law. We may charge aminimalfee to cover our costs of providing access to you.Where an individual has successfully demonstrated that the personal information is incorrect, we will take reasonable steps to amend any personal information that is incorrect. In some circumstances, we may not permit access to your personal information or we conclude that a correction to your personal information is not warranted, in which case you will provide you with reasons for this decision. If we correct your personal information, where appropriate, the amended information shall be transmitted to third parties having access to the information in question.

Personal Information that you delete from your user profile is deleted in a manner similar to emptying the recycle bin on a computer. That removed personal information may persist in backup copies on our secure servers for a reasonable period of time. Buchanan Group shall take care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information.

If you have corrections to make with respect to your personal information or with any questions about our privacy policy you may contact us at privacy@hometesterclub.com or in writing at:

Attn: Privacy
Buchanan Advertising (Canada) Inc
461 King Street West, Suite 402
Toronto, Ontario M5V 1K4 Canada
T: + 1 416 644 8686
F: + 1 416 596 8795

Updated August 2014

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