Charter of Personal Privacy
Effective date: July 11, 2022
TABLE OF CONTENTS
1. SCOPE AND APPLICATION
Belron Canada is part of Belron International Limited, a global company and the world leader in vehicle glass repair and replacement, with global offices in the United Kingdom (the “Belron Group”).
This Policy relates to personal information collected by Belron Canada. It applies whenever you interact with us, for instance, if you visit our service centres, if you visit www.belron.ca or any of our banners’ website (collectively our “websites”), if you use any Belron Canada mobile applications (“mobile apps”) or if you apply for a career opportunity with Belron Canada through an applicant tracking software and recruiting platform or through any other means.
In this Policy, we describe our policies and practices with respect to the collection, use and disclosure of personal information and the measures taken to ensure its continued protection. We also describe the rights and choices you have regarding your privacy.
In some cases, at the time of collection of your personal information, we may provide you with additional information regarding the processing of your personal information. We may also, in certain circumstances, obtain your specific consent for the use or sharing of your personal information, including where required by law.
2. WHAT IS “PERSONAL INFORMATION”?
In this Policy, “personal information” generally means information about an identifiable individual or natural person. This may include, for example, your name, contact information, home address, email address, birth date and your Vehicle Identification Number. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.
3. WHAT CATEGORIES OF PERSONAL INFORMATION DO WE COLLECT?
We collect personal information in a variety of ways detailed below under How we collect your personal information. We may collect the following personal information about you depending on your interactions with Belron Canada (for instance, if you are a client, a website visitor or a job applicant):
Personal identifiers, such as name, address, phone number, email address, username or similar identifiers, or vehicle identification number (VIN).
Demographic data, such as date of birth or gender.
Financial information, such as your bank account and payment card details.
Transaction history and profile information, such as details of payments to and from you and, details of products and services you have purchased from us, information about your vehicle or your preferences.
Internet or other electronic network activity information regarding your interaction with our websites and mobile apps, such as browser type, operating system, Internet or mobile service provider, referring/exit pages, pages viewed, Internet Protocol (IP) address, crash reports and system activity.
Geolocation information, which we may collect through our websites or mobile apps if you authorize us to do so.
Professional or employment-related information, such as information about your work experience and education, and any other work-related information you provide when you apply for a position with Belron Canada.
Account and profile data, such as information which relates to your account or profile on our websites and mobile apps, such as purchases or appointments made by you, your preferences, feedback and survey responses.
Any other information you may provide, such as feedback and survey responses.
4. HOW WE COLLECT YOUR PERSONAL INFORMATION?
We collect personal information in a variety of ways, including directly from you, from third parties and through our websites and mobile apps.
We may collect personal information from the following general sources:
a. Directly from you
We may collect personal information directly from you either in person (at our service centres or otherwise), via our websites or mobile apps, by telephone or via hand-held electronic devices used by our technician population. This could include personal information that you provide when:
you book an appointment with us or you request a quote from us, including through our websites or mobile apps;
you submit a photo of your vehicle glass damage;
you visit one of our service centres;
you communicate with us by phone or email;
you log into your account through our websites or mobile apps;
you contact us with an inquiry or share feedback with us through our websites or mobile apps;
you enter into a contest or promotion;
you complete a satisfaction survey (which may be conducted on our behalf by a third-party survey firm);
you request information on our products and services; or
you apply for a career opportunity with us, including through our career website (See available positions).
b. Automatically through technologies used at our service centres
We may collect personal information through various types of technologies used in our service centres. These can include video surveillance, sensors or other similar types of systems that we may use from time to time.
For example, we may use video surveillance (CCTV) in and around our service centres and areas surrounding our premises for security purposes, to protect against theft, to prevent damage to our properties, and to prevent fraud.
c. From third parties
In certain circumstances, we may collect personal information from third parties, for instance:
Insurers, insurance brokers and vehicle leasing organizations with which you have a contract, where those organizations have shared your information with us to assist us in providing a service to them and to you.
Social media platforms (such as Facebook, Twitter and Instagram), for example where you share our content through social media or “like” us on Facebook or follow or tweet about us on Twitter.
Providers of technical, payment and delivery services, such as Moneris.
d. Automatically through cookies and similar technologies
We may collect certain types of information electronically when you visit our websites or use our mobile apps, using cookies and other similar technologies. Please see our Cookie Notice for further details.
5. HOW WE USE YOUR PERSONAL INFORMATION?
We may use your personal information for the following purposes or otherwise with your consent or as permitted or required by law:
a. General business purposes
We may use your personal information for general business purposes such as providing or delivering a product or service requested from Belron Canada, managing our business and websites and mobile apps, preventing or reducing commercial risk, for purposes relating to information, system or network security, as well as to process job applications.
More specifically, we may use your personal information for the following general business purposes:
Providing or delivering our products and services. We use your personal information for activities that are necessary to provide or deliver our products and services, for instance:
Registering you as a new customer and processing your order.
Processing and performing any service you have booked.
Sending you appointment reminders or confirmations.
Making or receiving your payments, fees and charges.
Providing you with information about products and services you have ordered (e.g. change of time of appointment).
Sending you information you have requested or dealing with your enquiries.
Ensuring information in our records is accurate and verifying previously given information when necessary.
Managing our business operations. We use your personal information for several reasons in connection with our business operations, which include:
Exercising due diligence to prevent or reduce our commercial risk, such as administering our good governance requirements or management and satisfying regulatory audits, assessments, requests or requirements.
Ensuring the security of our information, system or network, including our website.
Complying with legal and regulatory obligations, requirements and guidance (e.g. health and safety legislation).
Facilitating the sale of one or more parts of our businesses, reorganizing our businesses and obtaining and submitting insurance claims.
Collecting a debt.
Managing and facilitating the use of our websites or mobile apps, including by using cookies and similar technologies. Please review our Cookie Notice for more details.
Processing your job application. When you submit a job application, we may use your personal information for the following purposes:
Verifying your identity.
Creating and administering your account.
Responding to your requests and communicating with you regarding your application.
Evaluating your application and making hiring decisions.
Concluding a hiring agreement.
b. Research and development purposes
We may use personal information to request your participation in surveys, which may be conducted on our behalf by a third-party survey firm, regarding the quality of our products, services or customer service.
We may also use personal information for internal data analytics purposes, for instance to identify usage trends, to measure the effectiveness of our communications, promotional campaigns and advertising and to improve our website, products and services, marketing, customer experience. For instance, we may use third-party web analytics services, such as Google Analytics, to help us analyze how visitors use our websites or mobile apps. When required by law, we will use anonymized or de-identified information for these purposes.
c. Marketing purposes
We may use your personal information to make suggestions and recommendations about products and services that may be of interest to you, deliver relevant website content and advertisements, and to communicate with you about offers, promotions, special events, programs or contests that may be of interest to you.
We may also use your personal information to communicate with you in a variety of ways (for example, by email, telephone, text message, direct mail or through our online client portal) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages. For more information on this topic, see What are your privacy choices?
6. WHEN DO WE SHARE YOUR PERSONAL INFORMATION WITH OTHER ORGANIZATIONS?
We may share your personal information within the Belron Group, with our service providers (companies that carry out activities on our behalf) and in the case of the sale or transfer of our business or another transaction. We may also share your personal information with your consent (for instance, with a fleet management partner, at your request) or in accordance with applicable law.
We may share your personal information as set out below:
a. Within the Belron Group
We may share personal information within the Belgron Group for the purposes described in this Policy, in order to streamline, harmonize and increase the quality, timeliness, accuracy and security of personal information throughout the Belron Group.
b. Other third parties with your consent
On the basis of your instructions, we may disclose your personal information to third parties such as our insurance and fleet management partners, an insurance broker or your employer.
c. Service providers
We may transfer personal information to our agents, vendors or other organizations that provide services to Belron Canada, for the purposes set out in this Policy. Service providers who may be provided with personal information may include, for example, payment card processors, appointment management providers, survey firms, document storage companies, backup and server hosting providers or IT software and maintenance providers.
d. Sale or transfer of our business or other transaction
We may decide to sell or transfer all or part of our business to a third party, merge with another entity, secure our assets or proceed with any other financing or other strategic capital transactions (including insolvency or bankruptcy proceedings), restructuring, share sale or other change in corporate control. We may share your personal information when required for the purposes of such a transaction.
e. Other permitted reasons
We may share your personal information when permitted or required by applicable law, for instance:
to law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights.
to third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties.
7. WHAT ARE YOUR PRIVACY CHOICES?
You have choices about the way Belron Canada handles your personal information.
a. Changing your communication preferences
You can always choose not to receive marketing or promotional messages from Belron Canada by email by clicking on “unsubscribe” in any email you receive.
Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with a service, in accordance with applicable law (for example, to send you an appointment reminder).
b. Changing your browser settings on your device
c. Restricting collection, use and disclosure of your personal information
You may withdraw your consent from the collection, use and disclosure of personal information in accordance with this Policy at any time upon reasonable notice to Belron Canada in writing, subject to legal or contractual restrictions.
The withdrawal of your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive because the continued use and disclosure of your personal information is a necessary part of making the product or service available to you. In some circumstances, legal requirements may prevent you from withdrawing consent.
8. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Belron Canada takes appropriate measures and controls aimed at safeguarding your personal information. These measures include restricting physical access to our offices and records, restricting access to your personal information to only those employees or agents who require access to fulfill their responsibilities, restricting unauthorized access, disclosure, use and misuse of your personal information in our custody and control, having archival documents stored with reliable third parties offsite at secure premises, using firewalls, passwords and file encryption for online activities.
Our goal is to prevent unauthorized access, loss, misuse, sharing or alteration of personal information in our possession. We also use these safeguards when we dispose of or destroy your personal information.
9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We store your personal information for as long as is necessary to provide our services to you, to manage our business operations, and to comply with our legal and regulatory obligations. For instance, we may need to retain your personal information to give effect to our lifetime guarantee. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).
10. CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION
We may share personal information within the Belron Group that are located outside of Canada. Some of our service providers may also access, process or store your personal information outside of Canada. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
11. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You may access your personal information and request the correction of inaccurate information, subject to limited exceptions set out in applicable laws.
To access and correct your personal information, please contact us in writing using the contact information listed in the Contact us section below. You may also access and correct your personal information through your account on our websites or mobile apps.
12. CHANGES TO THE POLICY
We may make changes to this Policy from time to time at our sole discretion. Any changes we make will be effective when we post the revised policy on our websites and mobile apps. If we make any significant changes to the Policy, we will post a notice on our websites and mobile apps or contact you to inform you when required by law. By continuing to interact with us after the modified version of the Policy has been posted, you are accepting the changes to the Policy, subject to any additional requirements that may apply. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy. The “Effective Date” at the top of this Policy indicates when it was last updated.
13. CONTACT US
If you have any questions or complaints about how we handle your personal information, please contact Belron Canada’s Privacy Officer at: Privacy@BelronCanada.com
Title and contact information of Belron Canada’s Privacy Officer:
Director IT Infrastructure
8288, boul. Pie-IX
Montreal, Quebec, H1Z 3T6