1. WHO IS IN CHARGE OF THE PROTECTION OF YOUR PERSONAL INFORMATION/DATA
2. WHAT PERSONAL INFORMATION/DATA IS COLLECTED
All our activities are based on stringent ethical principles and we are committed to providing a good level of protection for the privacy of all visitors to our website and our (mobile) applications. For this reason, the way in which we collect and store information is dependent on how our website and related services are used.
2.1 DATA COLLECTED BY AUTOMATED MEANS
Various technologies may be used on our websites and our (mobile) applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally contain personal details about the user. Examples of such technologies are cookies, flash cookies and web analytics.
2.1.1 CLICK-STREAM DATA
A visit to one of our websites results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
- the visitor’s IP address
- the date and time of the visit
- the referral URL (the site from which the visitor has come))
- the pages visited on our website
- information about the browser used (browser type and version, operating system, etc.).
2.1.3 FLASH COOKIES
A special form of cookie is the so-called flash cookie. In contrast to normal cookies, these cookies are not created and saved by the browser but are governed by the Adobe Flash plug-in. These can contain more information than normal cookies and cannot be deleted or disabled via the browser; this is only possible using tools such as the Adobe Flash Player website. You can also obtain more information about these cookies on that website.
2.1.4 WEB BEACONS AND TRACKING LINKS
Web beacons (also known as pixel tags and clean GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our website or (mobile) application. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
2.1.5 WEB ANALYTICS
Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and (mobile) applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or (mobile) application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Adobe Site Catalyst and/or other selected parties. You can find out more information about the processing of web analytics data by Adobe Site Catalyst in section 9 below.
2.2 PERSONAL INFORMATION/DATA PROVIDED BY YOU
Besides the data collected by automated means, we also process data that you have voluntarily provided to us during your use of the website (including your participation in forums, chatrooms and online contests). This includes, but is not limited to, certain personal information (such as your (first and last) name, preferred language, postal address, email address and, optionally, your telephone number or date of birth).
3. HOW IS THE COLLECTED DATA USED
We collect, use or disclose your personal information/data with your permission for the purposes identified, or as allowed or required under the law. Your permission may be expressed in writing or implied and you may give it to us verbally or electronically. If you have provided us with your personal information/data in relation to a promotion, event, (mobile) application, etc., we may send you emails or other messages that relate to the service you have requested.
If you contact customer service, we will use your personal information/data (including your contact history) so that customer service is able to process your request and provide you with the best service possible.
When you provide us with your personal information/data for purposes in relation to a promotion, event, application, etc., we assume that you consent to the collection of your personal information and its use for these purposes.
If you have opted-in to receive our newsletters and promotional emails, then we will send them to you. You can immediately unsubscribe from any of these notifications at any time at no cost by clicking on a link in the corresponding e-mail or other message (see further below in paragraph 5).
If we have consent to contact you (whether express or implied as required by applicable law), we may contact you per regular mail, e-mail, SMS, telephone or any other electronic means for marketing, advertising and opinion research purposes of Tribe. This includes, for example, information related to products of Tribe, e-commerce activities, special offers, promotions as well as information on local store openings, local store activities of Tribe or sporting events. In order to be able to contact you with information that is of special interest for you, your overall interaction with Tribe (such as but not limited to your ratings and reviews of products, your contact history with our customer service, your newsletter clicks/ opening results, your surfing behaviour (web tracking), the newsletter types you are subscribed to, your participation in promotions or events, your use of (mobile) applications), will be combined analyzed and used. We may provide your contact data to Tribe for marketing, advertising and opinion research purposes. Please find in section 5 information on your rights and especially on how you can withdraw your consent.
4. DISCLOSURE OF INFORMATION
One of our core principles states that your personal information/data will be treated with confidentiality. We will not sell your data to third parties. If required by law, your data will be disclosed to third parties. Where personal information is stored or processed outside of Canada (whether by Tribe or a service provider or data processor as outlined below), it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies. If required due to business requirements and provided that it is allowed under applicable law, we will transfer your data to other companies of Tribe. In all other cases, data will not be transferred without obtaining your prior consent.
We may use service providers and data processors working on behalf of Tribe. The services can include hosting and maintenance services, analysis services, e-mail messaging services, address check, administration of games and promotions, etc. These third parties may be authorized to collect personal data on behalf of Tribe and are granted access to such personal data they require in order to be able to carry out the particular service.
The service providers and data processors are contractually obliged to treat such information in the strictest confidence. It is also contractually forbidden for them to use the data in any other way than required. The necessary steps are taken to ensure that our service providers and the processors working on behalf of Tribe protect confidentiality of your data.
There may be occasions on which we disclose non-personal data to our partners in an anonymous form. Such non-personal data includes, for example, information about the number of visitors to a website or a (mobile) application during a certain period of time. Such information is generally only disclosed in a ‘bundled’ form.
5. YOUR RIGHTS
5.1 RIGHT TO OBJECT
E-mails that Tribe sends to you that contain for instance a newsletter or marketing content, include the option to terminate the receipt of such e-mails (unsubscribe) by following the relevant instructions in the respective e-mail. If you want to stop receiving emails from us, you can simply click on this unsubscribe hyperlink and we will stop sending you emails forthwith.
If you do not wish information about your behavior at our website or (mobile) application being collected and assessed, you can opt-out of the gathering of the web analytics data as described below in section 9.
If you wish to object to receiving promotional information and offers in general, so including by regular mail, e-mail, per SMS, by telephone or by any other electronic means, or if you want to withdraw your consent, you may do so at any time by e-mail to firstname.lastname@example.org. In case we have doubt about your identity, we can ask you to identify yourself (e.g. by sending a copy of your passport ID).
With regard to other types of messages you may receive, such as maintenance announcements or administrational notifications, the receipt of these can only be terminated by deleting your account as such messages are a mandatory part of user accounts and the related use of our websites and (mobile) applications. You can have your account deleted by sending an email to email@example.com.
5.2 RIGHT TO REQUEST INFORMATION
You have the right to be informed at any time about the personal information/data stored about you, its origin and recipients, as well as the purpose for which it is being stored. Information about stored personal data can be obtained by using the contact details in the Contact Information section 12 below. We may not be able to provide the information we hold about you if: (1) it contains references to other persons; (2) it is subject to solicitor-client or litigation privilege; (3) it contains proprietary information; (4) it has already been destroyed, (5) it is too costly, in our determination, to retrieve, and (6) it cannot be disclosed for legal reasons.
5.3 RIGHT TO REQUEST CORRECTION
You have the right to request to correct, supplement, delete or block the personal information/data stored about you. We will notify you within four (4) weeks of receiving the request as to whether and, if so, to what extent, we will comply with your request. If for any reason we don’t comply with your request, we will provide you with the reasons.
6. SECURITY OF THE INFORMATION AND DATA INTEGRITY
We take appropriate technical and organisational measures to protect personal information/data against accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.
7. PROTECTION OF CHILDREN’S PERSONAL DATA
The protection of children’s personal data is extremely important. Tribe understands that it has a responsibility to protect the privacy of children and has no intention of collecting the data of children under the age of 16. We also encourage parents and other guardians to surf the Internet together with their children and participate with their children in the multitude of activities offered by the wide range of websites on the World Wide Web.
If a child under the age of 16 attempts to register himself or herself, he or she is initially asked to provide the information as described in the above section 2 entitled “What personal information/data is collected”. In addition, the data submitted by and collected about the child during the course of his or her visit (e.g. via cookies) may be used as described above.
In addition, if a child under the age of 16 attempts to submit a registration application, this will be rejected with the notification that applications from children under the age of 16 are not accepted. For that reason, we ask parents and other guardians to check on and monitor their children’s Internet usage in order to protect them.
8. SOCIAL NETWORKS
Our website and (mobile) applications provide you Social Plug-ins from various social networks. If you choose to interact with a social network, your activity on our website or via our (mobile) applications will also be made available to social networks such as Facebook and Twitter.
If you are logged in on one of these social networks during your visit to one of our websites or (mobile) applications, the social network might add this information to your profile. If you are interacting with one of the Social Plug-ins, this information will be transferred to the social network. In case you do not wish such a data transfer, please log off on your social network before you enter one of our websites or (mobile) applications.
We cannot influence this data collection and data transfer via the Social Plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.
Google +: http://www.google.com/intl/en/policies/privacy/
9. GEOLOCATION SERVICES
We offer location-enabled services within some of our (mobile) applications, such as Google Maps and Bing Maps. If you use those (mobile) applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location. You are always asked if the Geolocation Service can be activated and you can also object to this Geolocation Service within the respective (mobile) application.
We use the Google Maps service or the Bing Maps service to assist you in finding the next Tribe store. To facilitate this, we load an image from Google Maps or Bing Maps, saving the route data and map image on our server.
Bing Maps: http://privacy.microsoft.com/en-us/fullnotice.mspx
10. CONTACT INFORMATION
Kanucks Gear Inc.
Contact our Consumer Services at: firstname.lastname@example.org
11. REGISTERING COMPLAINTS
You may register a privacy-related complaint by contacting the Group Data Protection/Privacy Officer at the above address or email address. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to correct the situation. We will also let you know what other complaint procedures may be available to you.
12. CHANGES TO THIS POLICY
Last revision, August 2019