Liberty Wine Merchants Inc.
Personal Information Protection Policy
At Liberty Wine Merchants Inc., we are committed to providing our customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers, protecting their personal information is one of our highest priorities.
While we have always respected our customers’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ personal information and allowing our customers to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Liberty Wine Merchants Inc.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Liberty Wine Merchants Inc.
Personal Information –means information about an identifiable individual, including name, age, home address and phone number. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Liberty Wine Merchants Inc. complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customer information that is necessary to fulfill the following purposes:
• To verify identity;
• To identify customer’s wine preferences;
• To deliver requested products and services;
• To open and manage an account;
• To send promotional newsletters to customers (if they have opted in);
• Ensure a high standard of customer service;
• Meet regulatory requirements;
• Collect and process payments for products and/or services;
Policy 2 – Consent
2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new products or services, and the customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers can withhold or withdraw their consent for Liberty Wine Merchants to use their personal information in certain ways. A customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s knowledge or consent in the following limited circumstances:
• When the collection, use or disclosure of personal information is permitted or required by law;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law;
• When we require legal advice from a lawyer;
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
• To contact our customers about products and services that may be of interest;
• To deliver products to customers via third-party courier;
• To send marketing materials and promotions via email;
3.2 We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use customer’s personal information to make a decision that directly affects the customer, we will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer’s personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.
5.2 Customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customers’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer personal information is appropriately protected:
• The use of locked filing cabinets where personal information is held;
• The use of SSL encryption through the website;
• The use of User IDs, passwords, restricting employee access to personal information as appropriate;
6.3 We will use appropriate security measures when destroying customer’s personal information such as shredding documents and permanently deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customers Access to Personal Information
7.1 Customers have a right to access their personal information, subject to limited exceptions:
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell customers how we use their personal information and to whom it has been disclosed if applicable.
Policy 8 – Mailchimp Privacy
8.1 Liberty Wine Merchants Inc. uses MailChimp to provide electronic newsletters to subscribers. In distributing newsletters, MailChimp will collect personal information from you, including email addresses you have provided to Liberty Wine Merchants for the purpose of receiving electronic newsletters, and all information relating to those email addresses.
• when you access Liberty Wine Merchants Inc. electronic newsletters;
• your browser type and version;
• your operating system and other similar information.
8.3 MailChimp will use the information collected from you for the purpose of hosting the online platform to enable Liberty Wine Merchants Inc. to create, send and manage electronic newsletters. MailChimp will also use this information to measure the performance of Liberty Wine Merchants Inc.’s email campaigns.
8.4 MailChimp may transfer this information to its contractors or other third parties who process the information on MailChimp’s behalf, or where otherwise required to do so by law.
8.6 You can unsubscribe from the Liberty Wine Merchants Inc. electronic newsletter at any time by selecting the “unsubscribe” option in every email sent to you by MailChimp.
Policy 9 – Questions and Complaints: The Role of the Privacy Officer or designated individual
9.1 The Privacy Officer is responsible for ensuring Liberty Wine Merchants Inc. compliance with this policy and the Personal Information Protection Act.
9.2 Customers should direct any complaints, concerns or questions regarding Liberty Wine Merchants Inc. compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Liberty Wine Merchants Inc. Privacy Officer or designated individual:
Liberty Wine Merchants Inc.
100 – 291 East 2nd Avenue
Vancouver, BC V5T 1B8
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This document was last updated in December 2020