Merjj Privacy Policy

ENGLISH

V04 – June 15, 2021

Human Contact Inc. / Merjj Inc.  (“Merjj”, “we” or “us”), the operator of Merjj website portal.humancontacthosting.com (the “Website”) on behalf of itself and of Human Contact Inc. / Merjj Inc. (each, a “Company” and collectively the “Companies”), is committed to protecting any personal information which you may provide while using, or that may be obtained from your use of, the Website or the emails sent by either Company to you. The purpose of this privacy policy (the “Policy”) is to: (i) inform you of the privacy practices and policies of the Companies, including how and why your personal information is collected, how your personal information is used and with which parties we may share your personal information; and (ii) provide you with contact information should you have questions or concerns about the practices of the Companies. This Policy is accessible via the Website.

This Website is for use only by residents of Canada. By using the Website, you consent to the collection, storage, use, disclosure and retention of your personal information in accordance with this Policy. If you do not agree with this Policy, you should not access or use the Website.

Overview of Our Privacy Practice

Our privacy practices are summarized here.  Under this Policy, the Companies:

  1. Requires that you confirm that you are the age of majority in your province of residence, or operating with the approval of your guardian who is age of majority in your province of residence;
  2. May collect data through your Website usage, your internet protocol (IP) address, the Website cookies and email web beacons;
  3. Collects non-identifiable information regarding Website users (such as the date and time you accessed the website);
  4. Shares this information with its authorized employees, agents, service providers and legal representations, and may also share this information with third parties that we engage to provide products and services on our behalf;
  5. May use, share and disclose the information collected by one Company to the other Company in accordance with this Policy;
  6. Except as set out in (d) and (e), does not share your personal information with third parties without your consent, unless authorized or required by law or as disclosed to you when the information is collected;
  7. Collects and uses this information to ensure that you and the recipient of our emails are of legal age to purchase tobacco products in their province of residence, comply with applicable laws and regulations, to administer the Website, to protect the Companies and Website users from fraud, to cross-reference with personal information provided by you to our sales representatives to ensure its accuracy, and to communicate with you;
  8. Stores your personal information with Human Contact Inc. or Merjj AWS server , and may store and process your personal information collected through the Website  on the servers of our third party service providers including Qumu, WebEx, Zoom, Microsoft; however, the third party service providers are only permitted to store your personal information, and are not otherwise authorized to collect, use or disclose your personal information, except in accordance with the purposes set out in this Policy.
  9. Allows you to withdraw your consent to the collection, use and disclosure of your personal information at any time; and
  10. Mitigates the risk and impact of potential harms involved in the disclosure of personal information through the adoption of reasonable physical, electronic and managerial procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide to us.  Even with these measures, there is a residual risk of the loss of, unauthorized access to or unauthorized disclosure of your information which could result in financial or other harm to you.

Further information with respect to our privacy practices is set out below.

1. Personal Information Collected by the Companies

Before you first access the Website, the Companies will provide you with a username and a temporary password.  When you log into the Website, you will be asked to confirm that you are of the age of majority in your province of residence and that you are an invited attendee, partner, customer or stakeholder conducting business with one or all of the Companies.  Once logged in, you will have access to a profile that was populated by the Companies based on the information you have provided to the Companies in the past when accessing or using other websites of the Companies.  The personal information pre-populated in your profile may include information such as your: name, address, billing address and contact information. In some cases, the Companies may ask you to provide additional information after initial registration, including your email address.

The Companies may also collect your Website usage data and your internet protocol (IP) address, and other similar information that you provide to the Companies via the Website, including information collected through the use of cookies on your browser.  As well, we may collect information relating to the emails that the Companies send to you, such as when you open the email, through the use of single pixel gifs (also called web beacons) or other tracking technologies.

You should exercise discretion when disclosing your personal information to us, and should not disclose sensitive or confidential information that you wish to remain private or that may require you to impose specific data security or data protection obligations on us.

2. Non-Identifiable Information Automatically Collected

The Website may automatically collect certain non-identifiable information regarding Website users, such as the date and time you access the Website, the consent to the Terms and Conditions of Use of the Website, the Internet address of the website from which you linked directly to the Website, the operating system you are using, the sections of the Website you visit, the Website pages read and images viewed, and the materials you download from the Website.  The Companies may collect, use, transfer and disclose aggregated and/or non-personal information.

3. Cookies

The Website uses “cookies”, a technology that installs information on a website user’s computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to track your activity at the Website in order to respond to your needs, to offer personalized web page content and information for your use, and to otherwise facilitate your Website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website.

4. Web Beacons

The emails that are sent to you may also include web beacons.  Web beacons allow the Companies to collect information about when email recipients open the emails sent to them, what parts of the email they review, their IP address, browser or email client type and other similar details.  Some of this information may be correlated with recipients’ email addresses.  The Companies use this information to review how recipients are responding to the emails sent to them.

5. Purpose of Collection and Use of Your Personal Information

Personal information that you supply during registration or that is collected through your use of the Website or from the emails sent to you by the Companies is collected and used for the following purposes:

  1. To ensure that users of the Website and recipients of emails from the Companies are of the legal age in their province of residence;
  2. As permitted by, and to comply with, applicable laws and regulations;
  3. To administer the Website, including the Rewards, Games and Contests sections, and to provide support for the services available through the Website and to manage the emails sent by the Companies;
  4. To protect the Companies and Website users against fraud;
  5. To contact you and to send you information about our products, our activities, programs and events (provided that you confirm that your email address is only accessible to adults in your province of residence and that you are an invited attendee, partner, customer or stakeholder conducting business with one or all of the Companies), unless and until you opt-out of receiving such information by contacting us at contact@humancontact.com;
  6. To send you online surveys;
  7. Other purposes permitted by law.

Personal information collected or disclosed to one Company may also be used by the other Company in accordance with this Policy.

6. Disclosure of Personal Information

The Companies will keep personal information that you provide to them private, and will disclose such personal information only in accordance with this Policy.

The Companies do not otherwise sell, rent, or lease to third parties any personal information collected from you. The Companies may disclose or share personal information with their authorized employees, agents, service providers and legal representatives for the purposes described in this Policy. They may also share your personal information with third parties that they engage to provide products and services on their behalf.

The Companies will not otherwise share your personal information with third parties without your consent, unless authorized or required by law or as disclosed to you when the information is collected. The Companies may disclose your personal information to a government institution or agency: (i) that has asserted its lawful authority to obtain the information or where a Company has reasonable grounds to believe the information could be useful in the investigation of unlawful activity; (ii) to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information or as required by the Companies to comply with their reporting obligations under applicable law; (iii) to comply with court rules regarding the production of records and information; or (iv) to protect the rights and property of all Companies. If a Company is involved in the sale or transfer of some or all of its business, the Company may disclose your personal information in connection with the transfer or sale.

7. How Your Privacy is Protected

The personal information collected about you is retained in confidence and the Companies have adopted reasonable physical, electronic and managerial procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide. Notwithstanding these measures, no collection or transmission of information over the Internet or otherwise can be guaranteed to be 100% secure, and therefore the security of any such information cannot be warranted or guaranteed.

8. Withdrawal of Consent

You may withdraw your consent to the collection, use and disclosure of personal information about you at any time. To do this, please contact the Privacy Officer at the e-mail address listed in this Policy.  Withdrawal of your consent to the collection, use and disclosure of personal information may result in you being unable to continue use of the Website or services.

9. Verifying and Amending your Personal Information

Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information held by the Companies and you may request that your personal information be corrected or updated. Please e-mail the Privacy Officer at the e-mail address listed in this Policy and we will assist you. You may be required to put your request in writing to confirm your request and identity. It is your responsibility to notify us of any changes to your personal information.

10. Retention of Personal Information

Your personal information will be retained in compliance with the Companies’ legal obligations, and only as long as necessary for the purposes for which it was collected.

11. Storage and Location of Information

You agree, acknowledge and consent to the transfer and storage of all personal information collected or used via the Website to Companies, where such information may be kept and may be accessed and used for any of the aforementioned purposes set out in this Policy. Please note that information collected or used via the Website, when and where under the control of Companies will be subject to the legislation of Canada, including legislation regarding the safeguarding of certain personal information, and may be disclosed to judicial and/or administrative authorities of such jurisdiction, where required by law.

The Companies may store and process your personal information collected through the Website on the servers of our third party service providers including Qumu, WebEx, Zoom, Microsoft or, from time to time, in other locations outside Canada that the service providers deems necessary or convenient in order to provide the services including but not limited to United States of America, and Europe. As such, foreign governments, courts, law enforcement or regulatory agencies may be able to access your personal information under foreign laws.  The third party service providers are only permitted to store your personal information, and are not otherwise authorized to collect, use or disclose your personal information, except in accordance with the purposes set out in this Policy.

You agree and acknowledge that the Companies have informed you as to the location where your personal information is kept and may be accessed and used as set forth herein above and that you may: (i) consult your personal information or request changes to it; or (ii) obtain information about the Companies’ policies and procedures with respect to the use of service providers or the collection, use, disclosure or storage of personal information by services outside of Canada; by making a written request to Human Contact Inc. / Merjj 1207 King St. West, Toronto, ON, M6K 1G2.

12. Privacy Policy Changes and Updates

This Policy may be revised at any time, without notice to you.  The Companies may, however, choose to notify you of a change to this Policy, for example by announcing the change on the Website.  Your continued use of the Website constitutes your consent to the contents of any updated policy.

Where we make significant changes to this Policy, we will notify you directly of the changes by sending you an email informing you of the changes, and will require your consent prior to the changes coming into effect.  Significant changes include using your personal information for a new purpose not anticipated originally or a new disclosure of your personal information to a third party for a purposes other than processing that is integral to the delivery of a service.

13. Role and Responsibilities of Each Company

Each of the Companies is entitled to the benefit of this Policy. The responsibilities of each Company under these Terms of Use are several and the responsibilities of each Company are not joint.

14. Resolving Your Concerns

If you would like more information about this Policy or the personal information collection, use and disclosure policies and practices of the Companies or their service providers, please contact the Privacy Officer at the following email address: contact@humancontact.com

Please let us know your questions or concerns and we will do our best to help you.