Ketchway Inc. (“Ketchway”) recognizes the importance of your right to privacy. We are committed to maintaining the privacy and security of any Personal Information we collect about you. It is an important aspect of the way Ketchway conducts its business.
Your privacy matters to us, so please do take the time to get to know our practices – and if you have any questions, please contact our Privacy Officer at firstname.lastname@example.org.
What Personal Information do we Collect and When?
"Personal Information" is any information that is about you or could be used to identify you, such as your name, telephone number(s), address(es), credit card number and expiry date, email address, pages viewed on our website, your purchasing history and any other personally identifiable information that you choose to provide to Ketchway.
How We Collect Your Personal Information and for what Purpose?
On the Phone
If you wish to unsubscribe from further communications at any time you may contact our Privacy Officer by e-mail at email@example.com.
Point of Purchase
When you complete a purchase or return, either on the telephone or online on our website, we may collect your name, email address (online only), mailing address(es), telephone numbers, payment card numbers and expiry dates and purchase history for the purposes of processing and completing your purchase or return transaction, processing and collecting your payment, fulfilling our legal obligations to report to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), communicating with you regarding orders, delivery and product repairs, understanding your preferences so that we may serve you better and improve upon our operational efficiencies, to recommend particular products or services to meet your needs and desires and to keep you informed of special promotions, product offerings and events at Ketchway. We do not keep or store your payment card numbers or expiry dates. Your payment card information is transferred directly to our payment processor or financial institution for the purposes of processing your payment transaction. To prevent unauthorized resale of our products and fraud, Ketchway may require you to provide information to verify your identity to complete a purchase or if you seek to return a product.
Third Party Cookies and Links
Email and Telephone Enquiries
When may Ketchway disclose Personal Information?
Transfer of your Personal Information Outside Canada
On occasion our Service Providers (defined below) may provide services in relation to the data outside of Canada. If you would like information on this, please contact the Privacy Officer.
Your Personal Information may be processed in Canada, the United States or France, and will be stored in servers on Ketchway's behalf hosted in various countries, including Canada, the United States and France. Your Personal Information may be subject to the laws of the countries in which it is stored or used. Those countries may have different data protection regimes than the country in which you reside. Under the laws of those countries, in certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. By providing us with any Personal Information, you acknowledge that it may be transferred outside Canada and you consent to the transfer of your Personal Information to servers located outside Canada, such as in the United States and France.
It is important to us that we collect, use or disclose your Personal Information where we have your consent to do so. Depending on the sensitivity of the Personal Information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.
As a general rule, Ketchway collects Personal Information directly from you. In those circumstances where any Personal Information about you is collected by, or received from, a third party (e.g. as part of an investigation), we will ensure we have your consent before we receive this information from such sources (such consent may be given directly by you, or implied from your actions) or we will take reasonable steps to ensure that such third parties have represented to us that they have a right to disclose that information to us.
Where permitted or required by applicable law or regulatory requirements, we may use, collect, store and disclose information about you without your knowledge or consent.
Additionally, at the time you provide your contact information, you will be given the opportunity to expressly consent to receiving information electronically by email at the email address(es) which you have provided to Ketchway, concerning any Ketchway products or services, promotions, newsletters, updates or other customer related materials. All communication to you by email will include an option for you to unsubscribe and withdraw your consent to receive electronic communications at any time.
You may also withdraw or vary your consent to the collection, use and disclosure of your Personal Information at any time, subject to Ketchway' legal or contractual restrictions, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and sent to our Privacy Officer at firstname.lastname@example.org. In some circumstances, if you choose not to provide Personal Information, or if you request a change or withdrawal of consent, our ability to provide products or services to you may be severely limited or made impossible.
Security and Retention
Ketchway endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question. These safeguards are designed to prevent your Personal Information from loss and unauthorized access, copying, use, modification or disclosure.
All financial information you provide, including on the Website, is not stored by Ketchway, but transferred directly and securely to Ketchway' payment processor or financial institution. Transactions conducted on the Website are protected by an SSL encrypting system. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by persons other than the intended recipient and may be subject to data corruption, interception and delays.
The security of your Personal Information is important to us, so please advise the Privacy Officer immediately should you become aware of any incident involving the loss or unauthorized access to or disclosure of Personal Information that is in our custody or control.
Personal Information will be retained only for so long as is reasonably necessary for the fulfillment of the purposes for which it was collected, or as required by law and Ketchway's record keeping policies. All destruction or removal of Personal Information from our records is done securely in accordance with the Ketchway's record keeping policies with due regard to the sensitivity of the information concerned.Ketchway may retain, for archival, record keeping, risk management and fraud prevention purposes, copies of communications with you through the Ketchway website, by email, over the phone or in person, and any response to questions or comments sent to you by Ketchway.
Ketchway will make reasonable efforts to ensure that Personal Information of individuals is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used, but we also rely on you to provide us with any changes to your Personal Information, and in particular to your contact information.
Access and Changes to your Personal Information
You may ask Ketchway to correct, update or delete (subject to our data retention requirements) any information you have provided to Ketchway by contacting the Privacy Officer. If applicable, you should be sure to provide Ketchway with any updates and changes to your information, including any changes to your postal or e-mail address to ensure that your orders are shipped to the correct address and that we can contact you about your order if necessary.
Your request should be in writing. Ketchway will respond promptly and will implement any unsubscribe request within 10 business days, or otherwise be in contact with you within 30 days, of receiving your request. It will amend any inaccuracy or incompleteness of Personal Information as required. Any unsatisfied requests shall be recorded by Ketchway. Specific requests for information can be directed to the Privacy Officer, and the information will be released within a reasonable time at minimal or no cost to you, depending on the nature of your request. If you have a sensory disability, we will work with you to provide you access to your Personal Information in an alternative format.
Ketchway may not be able to provide you with access to your Personal Information in certain circumstances. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Information that we hold about you. In addition, the Personal Information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your Personal Information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
Inquiries or Concerns
If you are not satisfied with the response of our Privacy Officer, your complaint can be escalated further. Contact us for more information about the appropriate Privacy Commission you may choose to contact.
Changes and Updates to Policy
Ketchway, in its commitment to privacy, has appointed a member of our team as Privacy Officer. The Privacy Officer is available to offer more information on our practices and policy, to ensure compliance and rectify any complaints. To communicate with the Privacy Officer, please see the contact information below.
If you have any questions, comments or concerns about privacy at Ketchway or to withdraw your consent for the use of your Personal Information please contact:
Ketchway Inc. Privacy Officer
Suite 300, 14505 Bannister Road SE
Calgary, Alberta, T2X 3J3
June 25, 2016