Privacy policy

This Privacy Policy (“Policy”) has been implemented and published on behalf of AUDREY+BRADLEY CO. and its affiliates (“Canadian Ammolite Gems”, “O2 Marketing Solutions Inc” “DK International Inc”, “we”, “us”, “our”, etc.). Our head office is located at Calgary, Alberta, Canada.

We value the relationship we have with our Customers and we are committed to reasonable and responsible handling of personal information in compliance with applicable privacy legislation. This Policy summarizes AUDREY+BRADLEY CO.’s practices with respect to individual privacy and personal information concerning Customers and other individuals who visit our website, or who otherwise provide us with personal information. This Policy does not apply to internal employment and other management activities of AUDREY+BRADLEY CO.

Definitions
·       “personal information“ means information about an identified or identifiable individual.

·       “Customer” means any person or entity which pays for Products.

·       “Products” means any and all products sold by us.

Collection, Use and Disclosure of Personal Information

It is our policy to only collect, use and disclose your personal information only after notifying you of the purpose for doing so and obtaining your consent unless otherwise required or permitted by law. We may collect, protect, use, share, and retain personal information, including name, billing address, shipping address, phone numbers, credit card numbers, email addresses and other personal identifiers appropriate in the circumstances, including security questions and credit bureau information if applicable, for the following purposes:

·       to verify identity, process orders and credit card payments, send confirming emails, ship Products, and provide requested products and services;

·       to open and maintain any account you may have with us with respect to purchasing Products;

·       to confirm and conclude contractual arrangements, collect money owed to us, and to troubleshoot any problems;

·       to respond to inquiries from you;

·       to carry out Customer surveys, in order to evaluate the needs, wants, and satisfaction levels of our Customers and to analyze and manage our business;

·       to provide and administer services and monitor your purchases, account and credit balances, fees paid and payable, payment history, parties to transactions, payments, credit card usage and to evaluate your credit eligibility with respect to the purposes set forth in this policy;

·       to implement, carry out and maintain security measures aimed at protecting you from identity theft, fraud and unauthorized access to your account;

·       to meet security requirements, including any legal or regulatory requirements;

·       to promote and market products and services offered by us and to communicate to you promotions, offers, customer experience content and new products or services.

Except as required for the foregoing, or as required or permitted by applicable law, we do not disclose personal information to third parties. We do not sell or rent our Customer lists to any third party. If you subscribe to periodic receipt of information from us, you may withdraw your consent at any time by notifying us through the channels provided by us for you to do so.

Our Website

We do not collect personal information from you when you simply visit our website. However, you should be aware that our server (and most web servers) does collect some information about you and all visitors, such as the browser and version you are using, your operating system, and your “IP” or Internet address, which may identify your Internet Service Provider or computer but generally not the person using it.

Our Website does use a technology called “cookies”. A cookie is a small file or token that our server may send to your browser when you access our Website. Cookies are capable of storing data and may be used to provide additional functionality to your use of our Website and can help us analyze your use of our Website usage more accurately. For example, cookies may be used to store your preferences so that on subsequent visits the Website displays for you in accordance with those preferences. Cookies may also tell us which pages are viewed more often or for longer periods of time than others.

Although we use cookies, we do not collect personally identifiable information from you except with your permission. If you wish to erase cookies, block cookies or receive a warning before receiving a cookie, most browsers will permit this.

While we make reasonable efforts to maintain the security of personal information in our custody or control, please be advised that the Internet and email are inherently insecure media, and we accept no liability for the security or privacy of personal information in transit over the Internet.

Unsolicited or Voluntary Personal Information

If you choose to voluntarily submit personal information to us by email, online forms or other means, which will generally be for the purposes of obtaining information, we will consider that you have done so with your consent for purposes reasonably related to your providing the information. If reasonable to do so, or if you request ongoing provision of information, after our initial response, we may communicate further with you with information that may be useful, but we will include instructions on how to terminate receiving such further information.

Outsourcing and Service Providers

·       We use third-party service providers to provide credit card and shipping services to process orders from you and ship Products to you. We require our service providers to comply with all applicable privacy laws.

·       We do contract with services providers and use servers located in the United States. By providing us with your personal information for the purposes described in this Policy, you consent to the transfer of your information to the United States, and to the storage of your information in the United States. For further information you may contact us as described below.

Accuracy and Completeness

When AUDREY+BRADLEY CO. collects, use or disclose personal information for billing purposes, AUDREY+BRADLEY CO. will make reasonable efforts to ensure that it is accurate, up to date, and complete.

Retention and Destruction

Alberta law allows AUDREY+BRADLEY CO., for legal or business purposes, to retain personal information for as long as is reasonable. Upon expiry of an appropriate retention period, bearing in mind reasonable legal and business requirements, personal information will either be destroyed in a secure manner or made anonymous. Should consent to AUDREY+BRADLEY CO.’s collection, use, disclosure or retention of personal information be revoked, Alberta law also allows AUDREY+BRADLEY CO. to continue to retain the information for as long as is reasonable for legal or business purposes. In the event that revocation of consent may have consequences to the individual concerned, and if reasonable to do so, AUDREY+BRADLEY CO. will advise the individual of the consequences of revoking their consent where it is reasonable in the circumstances to do so.

Security and Personal Information

AUDREY+BRADLEY CO. recognizes its legal obligations to protect confidential information and personal information in its custody or control. AUDREY+BRADLEY CO. has therefore made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.

Notification of Loss or Unauthorized Access or Disclosure

Where an incident occurs involving the loss of or unauthorized access to or disclosure of personal information under the control of AUDREY+BRADLEY CO., where a reasonable person would consider that there exists a real risk of significant harm to an individual as a result of the loss or unauthorized access or disclosure, AUDREY+BRADLEY CO. will, without unreasonable delay, provide notice to the Information and Privacy Commissioner for Alberta of the incident, including any information required by law at the time to be provided to the Commissioner. While Alberta law provides that the Commissioner has the authority to require AUDREY+BRADLEY CO. to notify individuals of the unauthorized access or disclosure, AUDREY+BRADLEY CO. may elect to immediately do so in the event AUDREY+BRADLEY CO. considers it reasonable in the circumstances.

Requests for Access to Personal Information

The law permits individuals to submit written requests to AUDREY+BRADLEY CO. to provide them with:

·       access to personal information about them under our custody or control by way of a copy of the record containing the information or by way of examination of the record;

·       information about our use or disclosure of personal information about them and the purposes for doing so; and

·       where it is reasonable to do so, if we have in our custody or under our control a record about an individual described in their request, the purposes for which their personal information under our custody or control has been and is being used by us, and the names of persons to whom, and the circumstances in which their personal information has been and is being disclosed by AUDREY+BRADLEY CO.

Requests must be in writing and include sufficient detail to allow us to identify any record in our custody or under our control containing the personal information requested. AUDREY+BRADLEY CO. has no control over information provided by Users in the course of using the Services and requests from Users will be directed to their applicable Licensee as that Licensee will have primary custody and control of User’s information. AUDREY+BRADLEY CO. does have control over billing and related information received from Licensees.

AUDREY+BRADLEY CO. will respond to applicable requests in the time allowed by Alberta law and will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements Alberta law permits AUDREY+BRADLEY CO. to charge. Where appropriate to do so, AUDREY+BRADLEY CO. may require advance payment of a deposit or the entire costs of responding to a request for access to personal information. AUDREY+BRADLEY CO. is not permitted to charge fees for corrections to errors or omissions in personal information.

An individual’s ability to access his or her personal information under the control of AUDREY+BRADLEY CO. is not absolute.

Alberta law provides that AUDREY+BRADLEY CO. is not permitted to disclose personal information where:

·       the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;

·       the disclosure would reveal personal information about another individual; or

·       the disclosure would reveal the identity of an individual who has in confidence provided us with an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity.

Alberta law further provides that AUDREY+BRADLEY CO. may choose not to disclose personal information where:

·       the personal information is protected by any legal privilege;

·       the disclosure of the information would reveal confidential commercial information and it is not unreasonable to withhold that information;

·       the personal information was collected by AUDREY+BRADLEY CO. for an investigation or legal proceeding;

·       the disclosure of the personal information might result in similar information no longer being provided to us when it is reasonable that it would be provided;

·       the personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act

·       under an agreement,

·       under a statute of Alberta, or of Canada, or of another province,

·       under a regulation of Alberta, a regulation of Canada or similar provision of the law of another province that, if enacted in Alberta, would constitute a regulation of Alberta,

·       under a legislative instrument of a professional regulatory organization, or

·       by a court; or the personal information relates to or may be used in the exercise of prosecutorial discretion.

Generally, Alberta’s privacy legislation states that it is not to be applied so as to affect any legal privilege so communications between AUDREY+BRADLEY CO. and its legal counsel and other records and documents subject to legal privilege will generally not be subject to disclosure.

Responses to Requests for Access to Personal Information

AUDREY+BRADLEY CO.’s response to requests for access to personal information will be in writing, and will confirm whether AUDREY+BRADLEY CO. is providing all or part of the requested information, whether or not AUDREY+BRADLEY CO. is allowing access or providing copies, and, if access is being provided, when that will be given. Where AUDREY+BRADLEY CO. is able to sever information it cannot or is not required to provide from information it is required to provide, AUDREY+BRADLEY CO. will provide the individual with access to the part of the record remaining after such information has been severed.

It is the policy of AUDREY+BRADLEY CO. to respond to requests for information within the time periods required by Alberta law,, but AUDREY+BRADLEY CO. reserves its rights to extend the time period where applicable law permits our doing so. Examples of where AUDREY+BRADLEY CO. can extend the time period include where the applicant does not give sufficient detail to enable AUDREY+BRADLEY CO. to identify the applicable records, or more time is needed to consult with another organization, a public body or a government or agency of a government of a jurisdiction in Canada.

If access to information or copies are refused by AUDREY+BRADLEY CO., AUDREY+BRADLEY CO. will provide written reasons for such refusal and the section of Alberta’s privacy legislation on which that refusal is based, along with the name of person who can answer questions about the refusal, and particulars of how the requesting individual can ask the Information and Privacy Commissioner for Alberta to review the decision of AUDREY+BRADLEY CO.

Requests for Correction of Personal Information

Alberta law permits individuals to submit written requests to AUDREY+BRADLEY CO. to correct errors or omissions in their personal information that is in the custody or control of AUDREY+BRADLEY CO.   AUDREY+BRADLEY CO. reserves the right to require sufficient information and detail from the individual in question in order to properly locate the information and provide a response.

In the event that an individual alleges errors or omissions in the personal information in the custody or control of AUDREY+BRADLEY CO., AUDREY+BRADLEY CO. will either:

·       correct the personal information and, if reasonable to do so, and not contrary to any legal or client privilege, send correction notifications to any other organizations to whom AUDREY+BRADLEY CO. disclosed the incorrect information; or

·       decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

Alberta law provides that corrections or alterations cannot be made to opinions, including expert or professional opinions, as opposed to factual information.

Amendment of Policy

AUDREY+BRADLEY CO. reserves the right to amend this Policy from time to time as required, and without notice, in order to better meet its obligations under applicable law.

Contacting of Communicating With Us

If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under the care and control of AUDREY+BRADLEY CO., please contact AUDREY+BRADLEY CO.’s Privacy Officer at:

Email Address: info@audreyandbradley.com