Holt, Renfrew & Co., Limited, (called in this statement “Holt Renfrew”), is committed to protecting your privacy and maintaining the integrity of any identifiable information we collect about you (“Personal Information”). Keeping our customers’ Personal Information and affairs in strict confidence is a cornerstone of Holt Renfrew’s business practices.
Our policies and procedures, which we practise in order to protect your privacy, are in place across Holt Renfrew. In the following pages we describe these policies and procedures and how we put them into practice so that you have control over how we collect, use and disclose your information.
Protecting your Privacy Means:
- We keep your information and the business you do with us in strict confidence
- your information is not sold
- you have control over how we obtain, use, and give out information about you
- you have access to the information we have about you
- we respect your privacy when we market our products and services.
A. The Collection of Personal Information
- Why does Holt Renfrew collect your Personal Information?
Holt Renfrew collects Personal Information and uses it in order to:
- Understand your needs and eligibility for products and services;
- Recommend particular products and services to meet your needs;
- Provide ongoing service;
- Improve service delivery;
- Answer your questions, queries or complaints;
- Review and evaluate job applications filed online through www.holtrenfrew.com;
- Provide you with information (e.g. through direct mail and/ or e-newsletters);
- Verify some of the information you give us;
- To avoid spam on our Blog;
- Establish your identification;
- Protect you and us from error and fraud;
- Where required, co-operate with law enforcement authorities, to comply with a court order or to prevent a breach of any applicable law.
- To let you know about promotions, offerings and contests. We may also automatically enter you in some of our contest(s). If you are automatically entered in a contest, we will let you know.
Certain information, such as a driver’s licence, although convenient for identification, is voluntary. It is up to you whether you want to provide this or other suitable identification, subject to any legal requirements.
We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.
We may review and analyze your use of products and services, to help us serve you better, and to bring other products and services to your attention, which we feel, will be of benefit to you. We also collect and analyze information from other sources for the same purposes.
Please note that aggregated information, where the identity of a specific individual cannot be determined, is not Personal Information. Holt Renfrew reserves the right to use aggregated information in any manner it thinks appropriate. For example, Holt Renfrew may also prepare aggregated user statistics or information summaries to describe our services and their popularity to our suppliers and prospective advertisers and for other lawful purposes. Any aggregated user statistics and information will not contain any Personal Information.
- What type of Personal Information does Holt Renfrew collect?
Holt Renfrew collects various types of Personal Information. For example, during the registration process with us, you will be asked to provide certain contact information (such as your name and e-mail address) and may be asked, depending upon which services you subscribe for or features you make use of, to provide additional contact information and general information about yourself (such as address, postal code, telephone numbers, age group, personal interests, personal preferences, product preferences and, with respect to the online job application feature specifically, work experience, formal education, training, certifications, skill set, abilities and other work related information).
- How Does Holt Renfrew Collect Personal Information?
Holt Renfrew may obtain and collect your Personal Information through a variety of means (e.g. you provide it verbally or in writing (including via electronic media)). The following are examples of how we may do so:
- The completion of manual or electronic forms. Forms you may be asked to complete include:
- Credit Card Applications: As a service to eligible customers, Holt Renfrew’s partner American Express may extend a credit card to eligible applicants. Holt Renfrew may be involved in such application process.
- Online Job Applications: Users of our website may search online for available positions at Holt Renfrew and submit job applications online with respect to such openings. Users who use such service will be asked to provide a cover letter, a resume and provide particulars as to their work experience, proficiencies and work preferences.
- Contests and Promotional Events: From time-to-time Holt Renfrew offers various promotions and contests. When participating in these promotions and contests, you may be asked to provide us with certain Personal Information. You are free at any time to have your Personal Information removed from our database or to have your name removed from our marketing distribution list on a go-forward basis.
- Clickstreaming: Clickstreaming is a technology that allows a website operator to track the paths that surfers take as they access a website and look at the site’s pages, and as they use links to other sites. Holt Renfrew collects such information from visitors to www.holtrenfrew.com and www.holtsmuse.com.
- Web Beacons: Web beacons are small, graphic images that allows a website operator to collect certain information and monitor user activity on its website. A web beacon is a very small pixel which is invisible to the user. Holt Renfrew uses web beacons in its e-newsletter and blog to collect non-personal information.
- Web site traffic information, which is monitored and analyzed in order to determine which features and services are popular and useful to visitors, so that we can improve our services.
Holt Renfrew may also prepare aggregated user statistics or information summaries to describe our services and their popularity to our suppliers and prospective advertisers and for other lawful purposes. Any aggregated user statistics and information will not contain any Personal Information.
- How Holt Renfrew May Disclose Personal Information
Holt Renfrew does not sell to third parties any Personal Information we collect. Holt Renfrew may transfer some information we collect to selected service providers, leased partners and suppliers who help us provide personalized services and advertising to you.
B. Your Consent
- Your Information is Obtained or Used Only With Your Consent
We obtain your consent before we:
- offer you other products and services
- send you information about products and services by means of direct marketing
- provided it is legally permitted, share your information in confidence within Holt Renfrew and with leased partners
- obtain, use or disclose to other persons, information about you unless we are obliged to do so by law or to protect our interests
- use your information in any way we did not tell you about previously.
Express consent can be verbal or written.
- You May Withdraw Your Consent After You Have Given It
The protection of your Personal Information is of the utmost importance to us. If you don’t want Holt Renfrew to use Personal Information collected about you for marketing or publicity purposes, please tell us at the time the information is collected.
You can withdraw your consent any time after you have given it to us, provided there are no legal requirements to prevent this. For information on how to proceed, you can call or email our Chief Privacy Officer at 416-960-2860 or firstname.lastname@example.org. You can also complete the PRIVACY INQUIRY AND INFORMATION CHANGE FORM and present it for processing to any sales associate or concierge(where available) at any Holt Renfrew store. Please note that you will be required to provide valid photo ID to verify your identity.
Please note, if you don’t consent to certain uses of information, or if you withdraw your consent, we may not be able to provide you with a particular product or service. If so, we will explain the situation to you to help you with your decision.
- We Ask for Your Consent Before Sharing Information With Other People
We may share information about you within Holt Renfrew and with selected vendors and our leased partners, however we do not release it to anyone outside of Holt Renfrew without your consent.
There are some exceptions to the above rule. For example, we may collect, use or disclose information without your consent if we:
a) use an outside company to process information
At times we may use the expertise of an outside company to do work for us involving some of your information. When we do, we select the company carefully and confirm that it uses security and privacy standards comparable to those of Holt Renfrew.
b) must disclose information for legal reasons
We may be compelled to release information by a court of law, or other legal or regulatory authority. If so, our policy is to release information only to the extent that we have to.
c) have to protect the interests of Holt Renfrew
In certain circumstances, Holt Renfrew may have to collect, use or release information for its protection. For example, we may do so to detect or prevent fraud.
d) use an outside company to provide you with a specific service
For example, to deliver a purchase to your home.
e) Sale or Transfer all or Part of Holt Renfrew
In some scenarios, Personal Information may be subject to transfer to another organization. This might occur, for example, in contemplation of a merger or a change of ownership of all or part of Holt Renfrew. We will do this only if the parties have entered into an agreement under which the disclosure of the information (including any Personal Information) is restricted to those purposes that relate to the business transaction and is to be used by the parties to carry out and complete the business transaction.
C. Verifying and Amending your Personal Information
- You Can See and Verify the Accuracy of Your Information
You can check your information to verify, update and correct it, and to have any obsolete information removed. We will ask you to put your request in writing by completing a PRIVACY INQUIRY AND INFORMATION CHANGE FORM . You can print the form by clicking here or request one from any sales associate or concierge (where available) the next time you are in a Holt Renfrew store. Once the form has been completed, it can be given to any sales associate or concierge (where available) for processing. Please note that you will be asked for valid photo ID to verify your identity.
Personal Information collected by our credit card supplier should be updated by calling an American Express representative at 1-888-834-2583.
There is no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records, which we have already given you. We will let you know in advance if there is a charge.
If you have a sensory disability, we will work with you to provide you access to your Personal Information in an alternative format.
It may not be appropriate for us to release certain information to you. Where information will not or cannot be disclosed, we will provide you with the reasons for non-disclosure.
If we have obtained information about you from other people, upon your request, we will let you know the person we got it from.
- You Can Find Out to Whom We Have Given Information About You
If you ask, we will let you know the names of outside companies or organizations we have given information to. This may include information given to outside companies we have used to do work for us, such as mailing houses.
- We Respond to Your Request Promptly
We will deal quickly with your request to see your information, and always respond to you within 30 days. If we need to extend the time, or we have to refuse your request, we’ll tell you why, subject to any legal restrictions and we will notify you of the new deadline, the reasons for the extension, and your rights under applicable legislation respecting the extension.
- We Update Your Information From Other Sources
Whenever possible, we will update any information obtained from any source. If a third party has given us information which you tell us is wrong, we will give you the name and address of that party so that you can correct the information.
- We Protect Other People’s Privacy When We Make Information Available to You
There may be files that include information about you and other customers, or that have information confidential to Holt Renfrew or are the property of Holt Renfrew. Because we must protect everyone’s confidentiality and legal rights, we cannot make these files available to persons outside of Holt Renfrew. However, we will make available to you any factual information about you contained in such files.
Holt Renfrew endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.
Holt Renfrew keeps the Personal Information we collect about you strictly confidential. Only authorized personnel have access to this Personal Information. Holt Renfrew and leased partners personnel who have access to Personal Information receive special training regarding privacy protection.
If any employee of Holt Renfrew or its leased partners misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses Personal Information – provided for the purpose of providing services to or for Holt Renfrew – this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between Holt Renfrew and that individual or organization.
Our computer security specialists build security into all our computer systems. This protects your information at all times, when it is stored in data files or handled by our employees. Our systems also protect your information when it is transmitted, for example, between our data processing centers, our stores and corporate offices.
Holt Renfrew has taken steps to protect the confidentiality of your on-line viewing. When you visit www.holtrenfrew.com or www.theholtsmuse.com, our websites are able to recognize your Internet service provider, but does not identify you as an individual.
We note that Holt Renfrew enables its customers in certain of its stores to connect to www.holtrenfrew.com or www.theholtsmuse.com through our Internet service provider. We cannot guarantee that any information that you may choose to disclose via the Internet will not be intercepted by third parties. We assume no responsibility for Personal Information disclosed through the Internet, which is intercepted, diverted or otherwise accessed.
E. Retention and Disposal
We keep your information only so long as we need it for the products and services you’re using, to offer you products and services when you are a customer and for a reasonable time thereafter, or to meet any legal requirements. We have retention standards, which meet these requirements. We destroy your information when it is no longer needed, or we remove your name from the information.
- We Are Committed to Upholding the Holt Renfrew Privacy Policies
If you have any questions or complaints about our privacy policies, or about how we are living up to them, let us know right away. Our privacy policies can be found on the Holt Renfrew websites at www.holtrenfrew.com and www.theholtsmuse.com, by writing or emailing the Office of the Chief Privacy Officer at Holt, Renfrew & Co., Limited, 60 Bloor Street West, Suite 300, Toronto, Ontario, M4W 3B8 or email@example.com and requesting a copy or by visiting any store.
- We Monitor Our Compliance With the Holt Renfrew Privacy Policies
We have procedures in place to assist our employees and leased employees in the practice of the Holt Renfrew privacy policies. Our practices will be reviewed on a regular basis and their findings will be reported to the Chief Privacy Officer.
G. Resolving Your Concerns
- Resolving Your Concerns Is Important to Us
Holt Renfrew is committed to treating you with the greatest respect and consideration, and providing the highest level of service. Please let us know about your questions or concerns and we will do our best to help you. Whatever the circumstances, resolving the problem for you is our primary concern.
- How to Resolve Concerns and Complaints at Holt Renfrewa) Talk to Us
In most cases completing a Privacy Inquiry Form will lead to the resolution of your concern. This form can be printed by clicking here or one can be obtained through any sales associate or concierge (where available) at your nearest Holt Renfrew stores
b) The Holt Renfrew Chief Privacy Officer Acts On Your Behalf
If your concerns have not been resolved to your satisfaction, feel free to write to The Chief Privacy Officer for Holt Renfrew as follows:
Holt Renfrew Chief Privacy Officer
60 Bloor Street West, Suite 300
Toronto, ON M4W 3B8
Fax the Office of the Holt Renfrew Chief Privacy Officer at: 416-922-3826.
The Holt Renfrew Chief Privacy Officer’s office will acknowledge your complaint. Then, providing legal action has not been taken on the matter, the Holt Renfrew Chief Privacy Officer immediately goes to work. You will receive a response within thirty (30) working days.
c) If You Are Not Satisfied With the Decision of Holt Renfrew’S Chief Privacy Officer Regarding Your Complaint
Should you not be able to accept the conclusion of Holt Renfrew’S Chief Privacy Officer, you can ask how your complaint can be further escalated.