Privacy Policy
1. OBJECTIVE AND SCOPE
Retail Media Group Ltd. and More Rewards Partnerships (collectively “RMG”) take your privacy seriously. This privacy policy (the “Policy”) describes how we collect, use, retain, disclose and destroy your personal information and the security measures RMG has in place to protect it.
RMG is responsible for the protection of personal information in its possession, whether it is held by RMG or by a third party, and regardless of its form. As such, RMG takes appropriate security measures to protect your personal information in a manner that is proportionate to its sensitivity and has adopted this Policy.
This Policy is divided into three general areas: (i) how we process your information; (ii) your rights with respect to your personal data; and (iii) information third party sites, and security measures, and similar issues that may impact personal data.
2. YOUR CONSENT
By visiting or using our websites: www.rmgi.ca ; www.rmgadvertising.com ; www.rmgloyalty.ca ; or www.morerewardspartnerships.ca (collectively our “Sites”), or by otherwise communicating with us, you agree to be bound by this Policy and consent to our collection, use, retention, disclosure and safe destruction of your personal information as outlined in this Policy.
You understand that certain features of our Sites or certain services or products carried by RMG may no longer be accessible or may be restricted following your refusal or withdrawal of consent from this Policy. Your consent is the legal basis for our use of your personal information. You can withdraw your consent at any time. However, if you withdraw your consent to certain uses, we may no longer be able to provide our services to you.
3. WHO WE COLLECT INFORMATION FROM
Visitors to our Sites, individuals who communicate with us including our employees, individuals who establish a relationship with us by telephone, sign up to receive communications, or who sign up for RMG services and customers of our Partners who have engaged us to deliver services on their behalf.
Children
Our Sites are not intended for children. If we become aware that we have inadvertently received or collected personal information pertaining to a child under the age of 14 without valid and verified consent from the parental authority, we will delete such information from our records.
4. WHAT PERSONAL INFORMATION WE COLLECT
Device Information
When you visit the Sites, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifer. For more information about cookies, and how to disable cookies, visit www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Loyalty Information
We may also receive personal information about you from our loyalty program partners (“Partners”) to the extent that you have given consent to the Partner to provide us with such personal information. This includes name, email, collector card number, and loyalty transaction information. We refer to this information as “Loyalty Information”.
Order Information
Additionally, when you request information, make a purchase, or attempt to make a purchase, we collect information input by you, which includes purchase and sale transaction information such as your credit card information and the details of your transaction. We refer to this information as “Order Information”.
General Information
Information contained in any email messages, questions, comments, complaints, or requests you send us. We refer to this information as “General Information”.
5. HOW WE USE PERSONAL INFORMATION
We will only collect and use your personal information for the following purposes, except as permitted or required by applicable law:
– processing transactions that have been submitted to us;
– acknowledging your comments and/or replying to your questions, complaints, and requests;
– communicating with you and providing you with information;
– direct marketing of special offers or promotions (including sweepstakes and contests) that we believe may be of interest to you;
– to serve advertisements to you in various marketing channels, including but not limited to social media, search engines, mobile apps, and various websites including our own Sites;
– for profiling and analytical purposes, including marketing and website analytics, in order to optimize and customize our online platform to your needs, as well as the products and services marketed to you, and to make the Sites easier to use;
– to provide customer service;
– improving the performance and utility of our services;
– generally managing and administering our business;
– preventing and prosecuting fraud and/or credit risk;
– meeting legal and regulatory requirements; and
– any other purpose to which you may consent in the future.
Limited to Disclosed Purposes
We limit the collection, use, and disclosure of personal information to that which is needed to achieve the above noted purposes.
6. WHO WE DISCLOSE PERSONAL INFORMATION TO
We will only disclose your personal information in the following circumstances, except as permitted or required by applicable law:
– to More Rewards and other third-party suppliers, as necessary to provide you with services that you have requested or to fulfill the transactions you have submitted;
– to third-party companies and contractors that provide us with services in the conduct of our business (“service providers”), such as payment processing services, information technology services for our software applications, advertising and marketing, and other essential similar services, but only as necessary for those service providers to provide services to us;
– to third parties as we deem necessary or appropriate to prevent, limit, or otherwise prosecute fraud;
– as necessary to meet legal and regulatory requirements; and
– any other circumstance in which you provide consent to disclose.
Any disclosure of your personal information to third parties will be done pursuant to agreements setting out the requirements for use, safeguarding, retention and disposal of such information, or as required by law. All RMG third-parties and service providers are contractually bound to keep your information secure. Our service providers can use, store, and disclose your personal information solely for purposes for which it is disclosed to them (to provide us with services). We have contracts in place holding these service providers to the same standards of confidentiality by which we are governed. In some cases, these service providers may be located outside of your province or Canada (such as in the United States).
7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We will retain your personal information for as long as:
– your personal information is needed to provide you services; or
– it is necessary to meet legal, regulatory, insurance, and audit requirements.
Once the purpose for which the personal information has been collected or used have been fulfilled, RMG will safely destroy or anonymize it in accordance with the relevant legislation.
If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at dpo@rmgi.ca
8. PROTECTING YOUR INFORMATION WITH SECURITY MEASURES
We take reasonable measures, including administrative, physical and technical safeguards, to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Personal information uploaded to our Sites is transmitted to us using industry standard encryption, which creates a private conversation between your computer and our Sites. We authenticate our Sites and enable TLS/SSL encryption to protect your sensitive data and transactions.
The information collected is protected by computer security measures that are reasonable in light of its sensitivity.
Physical and physical security measures include:
– restricted access to our offices, records and locked filing cabinets;
– restricting access to your personal information to a selected group of people;
– written contractual obligations with third parties who require access to your personal information, requiring them to protect, through security measures, the confidentiality and security of your personal information and to use it only for the purposes of the contract, mandate or service they are performing;
– [other measures you use].
Computer security measures include:
– the use of passwords;
– file encryption;
– restricted access to our data processing and storage rooms;
– regular review of our security practices;
– regular updating of our technology;
– [other measures you use].
Nevertheless, RMG cannot absolutely guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that your personal information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify you and take other steps in accordance with applicable laws or regulations.
Remember that email sent over the Internet is generally unencrypted and transmitted in clear text. We recommend that you use caution when forwarding free-format email messages to us and that you do not include confidential information (such as unique user IDs, passwords, or personally identifiable information) in those messages. Confidential information should be transmitted to us through other secure methods.
9. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION
You are entitled to be informed or and have access or to rectify the personal information we have in our custody or control. If you wish to access or obtain a copy of your personal information, or if you wish us to rectify any of the personal information we hold about you that is inaccurate, you may do so by contacting us. Upon written request to our Data Privacy Officer as noted at the bottom of this page, we will provide you with your personal information under our custody or control, as well as information regarding how your personal information is being used and the identity of any third party(s) to whom that information has been disclosed.
We are committed to maintaining the accuracy of your personal information and ensures that it is complete and up-to-date. If you wish to change or update your personal information, you may request to do so at any time. Please note that we may only alter that personal information required to fulfill the stated purposes.
Please note that we may not be able to provide access to personal information in certain circumstances, such as if the personal information was collected for the purposes of an investigation, if disclosure would reveal the personal information of a third party, or if prohibited by law. To protect your privacy and security, we may take reasonable steps to verify your identity prior to providing such access.
You may change or withdraw your consent for the collection, use and disclosure of your personal information at any time, subject to reasonable notice, by contacting our Data Privacy Officer. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products RMG is able to provide to you.
10. YOUR RIGHTS – FOR EUROPEAN RESIDENTS
In addition to rights with respect to your personal data already noted elsewhere in this policy, for those individuals residing in the European Economic Area, you have certain additional rights under the General Data Protection Regulation (GDPR):
Restrictions on Further Processing
You have the right, where there is a dispute in relation to the accuracy or basis of processing of your personal data, to request a restriction on further processing by us.
Erasure
You have the right to erasure of your personal data (“right to be forgotten”) in certain circumstances.
Data Portability
You have the right to request that personal data that you have provided to us be returned to you or be provided to another third party of your choice, in a structured, commonly-used, and machine-readable format.
Automated Decision-Making
You have the right not to be subject to a decision based solely on automated decision-making. In connection with such right, you may have the right to request human intervention with respect to such automated decision-making, as well as express your point of view or contest any such automated decision-making.
Opt-out of Direct Marketing / Profiling
You may elect to “opt out” of direct marketing activities, including any profiling we may conduct for direct marketing purposes. Accordingly, we may rely on your consent permitting us to process your information in accordance with this policy for direct marketing, including profiling for direct marketing, unless you take affirmative action to opt out of such processing. You may opt out at any time by contacting our Data Privacy Officer as provided further below in the Contacting Us section.
Lodge Complaints with Supervisory Authorities
You have the right to lodge a complaint with a data protection supervisory authority in your country.
11. LINKS TO THIRD PARTY SITES
We may provide links or references to third party sites whose privacy practices may differ from those of RMG. RMG assumes no responsibility for the content or the privacy policies of those Partner or third-party websites. Please be aware that when you follow any links to another site not owned or operated by RMG and submit personal information to any of those sites, you are subject to their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
12. SOCIAL MEDIA FEATURES
Our Sites may include social media features, such as the Facebook button and widgets, among other things. These features may collect your IP address, track which page you visit on our Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy policy of the company providing it. We encourage you to carefully read the privacy policy of any company that provides the features you choose to interact with.
13. REVISION OF POLICY
This Policy may be revised from time to time. We will notify you of material changes prior to such material change being effective, either by e-mail at the address you have provided to us in connection with your registration on our Sites or by a prominent notice on our Sites. Should the modifications affect the initial consent, we will collect a new consent from the user, where required. We encourage you to periodically review this page for the latest information on our privacy practices.
14. CONTACT INFORMATION AND COMPLAINTS
The Data Privacy Officer is accountable for our compliance with this Policy and applicable privacy legislation. If you have questions, comments, or complaints with respect to our Policy or if you wish to request access to, or correction or deletion of your personal information under RMG’s care and control, obtain a copy of your personal information or exercise an option or right with regards to it, please contact the Data Privacy Officer.
Any concerned individual may file a complaint with the Data Privacy Officer. Complaints must indicate the nature of the complaint, the date on which the incident occurred, and the expectations for resolution. The Data Privacy Officer acknowledges receipt of the complaint and processes it within a maximum of 20 days. We investigate all privacy complaints and take appropriate steps to resolve them. For further information, please contact the Data Privacy Officer at:
Data Privacy Officer
dpo@rmgi.ca
Retail Media Group
4521 Manhattan Rd SE,
Calgary, AB
Canada
(403) 217-4373 x 202
This Policy was last updated on September 22, 2023.