Privacy policy

Effective Date: 30 August 2024

At Btrust Supermarket, we respect your privacy and take great care in protecting your personal information. This policy demonstrates our commitment to your privacy. Read on to discover how your Personal Information is being protected.

Customers rely on us to safeguard this information and ensure its responsible collection and use. To do so, we have committed to the following principles:
1. We will be transparent about how we handle your Personal Information and our privacy practices.
2. We will use your Personal Information to benefit you and enhance your customer experience.
3. We will protect your Personal Information and handle it responsibly.

We also want to be transparent about how you can help manage your privacy and information, so you can make informed decisions.

Below is the full Btrust Supermarket Privacy Policy for more information.

1.        Scope And Application

This policy relates to the customer Personal Information collected by BTRUST Supermarket, including its websites and mobile applications. Throughout this policy, we may refer to BTRUST Supermarket as “BTRUST”, “we”, “us” or “our”.

In this policy, we describe what Personal Information we collect; how we use, share and manage it; how you can access, update and/or correct your Personal Information; and the privacy choices available to you.

Please also refer to any privacy statements available at our locations, websites or mobile applications available to you at the time your Personal Information is collected.

A.     What does this privacy policy include?

This policy describes how we handle your Personal Information, specifically, what we collect, and how we collect, use, share, protect and store it. We also explain your Privacy Choices and how you can exercise those choices.

This policy applies to you when you visit one of our websites, use our app, sign up to be a part of any of our programs, promotions, contests or events, apply for or purchase our products or receive our services.

2.      What type of personal Information do we collect and how?

 

We limit the collection of Personal Information to what is reasonably required to fulfill the purposes for which it was collected. We collect Personal Information, as defined below, in a variety of ways, including directly from you, from third parties, through in-store technologies, and when you are interacting with us online or through our mobile applications.

 

A.      How we define personal Information?

“Personal Information” is any information that identifies you or could be reasonably associated with you and includes non-Personal Information that we link to Personal Information. We need to collect, use and disclose certain Personal Information about you in order to serve you, provide products and services, and meet our legal obligations.

B.      Categories of Personal Information  that we collect

 

Examples of personal information we collect may include:

 

Information Type	Example
1.      Identification Information	·         First name ·         Last name ·         Birth Month
2.      Contact Information	·         Email address ·         Mailing address ·         Phone number
3.      Authentication information	·         Passwords ·         Responses to authentication questions
4.      Information about your interactions with us	·         Responses to surveys and questionnaires ·         Video recording from Btrust security cameras ·         Written communications via email or chat
5.      Information collected through your interactions with our websites and applications	·         Information collected through cookies ·         Browsing preferences (language, province, etc.) ·         IP address
6.      Information about the Btrust products and services	·         Order history ·         Purchase history ·         Transaction information

 

Some categories listed are only collected when we provide particular products and services. If you do not own, use, or acquire these products or services, we will not collect that Personal Information. If you do not provide consent to collect certain information, we will not collect it.

 C.     How do we collect personal information?

We collect Personal Information in the following ways:

·         Directly from You

You may provide Personal Information to us in our stores, by mail, by email, over the telephone, through our websites or mobile applications or in any other direct manner.

·         From other sources

We may receive Personal Information from other sources with your consent or if the law requires or permits us to do so (e.g., to meet our anti-money laundering compliance or other legal and regulatory obligations).

In order to ensure the accuracy of the contact information that you provide us, such as your name, email address and phone number, we may retain the services of a service provider to verify and, if necessary, update, complete or otherwise supplement your contact information by providing us with such additional information. This helps us protect you against error and fraud, and to manage our business operations by ensuring that we can reach you in case of an issue in connection with our programs, products or services, or as otherwise permitted by applicable law, as described below in the How Do We Use Personal Information section.

·         From Technologies Used at Our Locations

We may collect Personal Information through various types of technologies used in our stores, including your image. These can include our point-of-sale systems, video surveillance or other similar types of technologies.

·         Through our website and mobile applications

We may collect certain types of information electronically when you interact with our websites, email, mobile applications, social media accounts, online advertising, or through the use of our or a third party’s technologies, which include cookies, web beacons, single pixel gifts and other technologies. This information helps us understand what actions you take on our websites and mobile applications and allows our website and mobile applications to work correctly.

We may combine this information with other information collected in-store or online such as your online and in-store transaction history, and aggregate demographic information, such as the predominant age groups and the average size of households in your area, which can help us gain insights about your interests and preferences. We do this to support our customer understanding using website and mobile analytics and to provide you with more tailored advertising and marketing communications. This includes serving interest-based advertising to you, subject to your right to withdraw consent, as detailed below in the Interest-based Advertising section

The technologies we use include:

·         Cookies, which are small text files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit our sites.

·         Web beacons, and single pixel gifs, which are small image files that have information about you, such as your IP address, that can be downloaded when you visit a website or open an e-mail. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e. in a manner that prevents us from identifying you personally). Aggregate information refers to Personal Information compiled and expressed in a summary form where no personal identifiers are included.

·         Other technologies, such as analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization, interest-based advertising, customizing content and other methods to gain insights into our customers’ needs and preferences.

We may use Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses cookies to analyze your use of our websites, to create reports about visitor activities for us and to provide further services associated with the use of the websites and the Internet. Although this information is collected through your Google ad settings, it is not provided to us in a personally identifiable format.

You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our websites or mobile applications.

3. How Do We Use Personal Information?

We use your Personal Information to provide you with our programs, products and services, to manage our business operations, to communicate offers and information we think might interest you, to generally enhance your customer experience with us and otherwise as permitted or required by law. We use your Personal Information for the following purposes:

A. Providing Programs, Products, And Services

We use your Personal Information to provide you with our programs, products and services, which include:

·         Providing you with a quote for a program, product or service;

·         Verifying your identity;

·         Determining your eligibility for a program, product or service;Validating the contact information that you provide us, such as your name, email address and phone number, through service providers to be able to communicate with you about programs, products or services;

·         Processing your applications;

·         Delivering programs, products and services;

·         Creating, administering, and maintaining your accounts (such as for our BTRUST Rewards program)

·         Processing your transactions and returns, online or in store; and

·         Fulfilling your product and service requests, inquiries, and purchases.

B. Interest-Based Advertising

Interest-based advertisements are advertisements from us or our customers relating to our products and services or third-party products and services that we hope you find more relevant to your interests. With your consent, we deliver interest-based advertisements to your device by using a cookie or other identifier assigned to your device.

We use the Personal Information of our customers to place them in general interest and purchase categories (e.g., beauty products buyers, coffee buyers, organic product buyers), which helps us determine what types of advertisements may be of interest to and then serve you with these advertisements. We may draw inferences from items purchased online and/or in-store and use these inferences to gain insights into how well our products or third-party products sell to a certain general interest group.

It is important to note that we will not use sensitive data (e.g., health information, financial account information, sensitive product information i.e. data about your personal lifestyle choices or products which may be of an intimate nature such as weight, political or religious affiliations, etc.), for interest-based advertising purposes, without your express consent. Examples of non-sensitive data include items such as groceries, cosmetics, and household goods.

Our client advertisers on whose behalf we may serve interest-based advertising through our service will never receive Personal Information about our customers since they only need to know that they are reaching the right customers at the right time and place to make their advertising relevant and whether their advertising campaign was effective. As such, our customers’ Personal Information always remains within our custody and control.

C. Managing Our Businesses

We use your Personal Information for many business reasons, which include:

·         Deploying and managing our information technology applications and systems, including managing our websites;

·         Managing and facilitating the use of our websites and mobile applications, which may include using cookies and other similar technology;

·         Enabling your participation in contests, promotions, surveys, chats, seminars or workshops;

·         Maintaining the security of the public and our customers, employees and property (e.g., through video surveillance);

·         Protecting parties from errors and fraud;

·         Monitoring and investigating incidents and managing claims;

·         Maintaining our programs, products and services, including our BTRUST Rewards program; and

·         Meeting our legal and regulatory obligations.

D. Communicating with you

We use your Personal Information to communicate with you in a variety of ways:

·         Providing you with information and updates about our programs, products, services, promotions, contests, and events;

·         Responding to your inquiries;

·         Informing you of public health concerns, where we believe an exposure may have affected one of our premises, in accordance with public health laws;

·         Taking or verifying instructions from you;

·         If we have your consent, informing you in a variety of ways (e.g., email, telephone, SMS, direct mail) about programs, products, services, special offers, promotions, contests or events that may be of interest to you;

·         Delivering interest-based advertisements relating to our products and services or third-party products and services that may be of interest to you. For more information see Interest-Based Advertising; and

·         With your consent providing you with offers or services based on the approximate location provided by your mobile device (also called “location-based advertising”).

If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message.

E. Conducting Market Research

We may use your Personal Information to conduct market research by tracking and analyzing current or previously collected information to improve or to develop new products, services, programs, promotions, contests or events and to better understand our customer base. When doing so, we generally will use your information in an aggregated format or with direct personal identifiers removed.

The information we use for market research may include:

·         Purchase history (e.g. the number and amount of transactions by type, location/store of purchase, product code information, brand, quantity purchased, date, time, payment method used, promotional offers used in connection with the transaction, etc.);

·         Website or mobile application activities (e.g. offers viewed, opt-out preferences, email bounce backs, click-throughs, content on social media, and IP addresses);

·         Account activity, balances and payment history;

·         Use of mobile devices interacting with our websites or mobile applications (e.g. use of features, and duration, frequency, type and location of calls and text messages); and

·         The methods used to apply for or to access or use our programs, products, services, promotions, contests or events.

F. Conducting Data Analytics

We may use your Personal Information to conduct data analytics or research for business purposes. Wherever possible, we use aggregated, anonymized or de-identified information and minimize the risk of re-identification.

The activities involving Personal Information under data analytics include:

·         Managing and developing our business and operations;

·         Improving our programs, products, and services (e.g. improving our websites and mobile applications);

·         Understanding customer needs and preferences and customizing how we tailor and market products and services to our customers based on their interests; and

·         Measuring the effectiveness of our marketing.

G. Automated Decision-Making

We may use various technologies to help us provide you with our programs, products, and services, to manage our business operations, to communicate with you and to enhance your customer experience with us. In most cases, these tools assist, but do not replace, human judgment in making a decision.

4. How Do We Share Personal Information?

We may share your Personal Information within the group of companies that BTRUST Supermarket Inc. is a member of or with our service providers (companies operating on our behalf) and other third parties (companies with which we provide programs, products or services) for the purposes described in this policy and in accordance with applicable law. We do not sell your Personal Information to any organization or person; the only exception to this would be if we sell or transfer any part of our business.

Additionally, if you use a program, product or service that involves another person (e.g., if you add household members to your BTRUST Rewards Account), we may share your Personal Information with that person as necessary and in connection with that program, product or service. The information shared with or available to these other persons will be identified at the time of application or registration for that program, product or service.

Categories of third parties and service providers with whom we may share personal information include:

·         Software service providers

·         Hosting service providers

·         Data storage service providers

We will not share your Personal Information outside of our group of companies, except as indicated below.

A. Service Providers

In the course of providing our programs, products, services, promotions, contests and events we may share Personal Information with our service providers, some of which may be located outside of your province or territory of residence, or outside of Canada. These service providers help us operate our business, technology systems and applications, internal procedures and infrastructure and advertising and marketing (e.g. payment, advertising and marketing partners). They provide services to us such as data hosting, contest administration, email deployment, call centre, marketing, sales and processing or analysis of Personal Information. We require these service providers to limit their access and/or use of Personal Information to what is required to provide their services and to comply with our privacy requirements.

B. Third Parties

In the course of providing our programs, products, and services, we may do so through arrangements with third parties, some of which may reside outside your province or territory of residence or outside Canada. As a result, your Personal Information may be collected, used, and shared by us and the applicable third party. These third parties may have their own privacy policies and terms and conditions, which will govern their use of your Personal Information. You will be informed upon signing up for the relevant program, product, or service of the third-party arrangement so that you can review the relevant privacy policies that apply.

C. Sale Or Transfer Of Business Or Other Transaction

We may decide to sell or transfer all or part of our business to a related company or to a third party, to merge with another entity, to insure or securitize our assets, or to engage in another form of corporate or financing transaction (including the proceedings of insolvency or bankruptcy), corporate reorganization, share sale or other change in corporate control. If your Personal Information is required in connection with any such transactions, we will comply with the legal requirements for the disclosure of Personal Information.

D. Other Permitted Reasons

Canadian law permits or requires the use, sharing, or disclosure of Personal Information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect our group of companies, our employees, our customers, or others. If this happens, we will not share more Personal Information than is reasonably required to fulfill that particular purpose.

E. With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your Personal Information outside of our group of companies, in accordance with applicable law.

5. How Do We Manage Consent?

By subscribing to our programs, products, and services and/or submitting information to us in connection with using our programs, products, and services, you are providing your consent to the collection, use, and disclosure of personal information as set out in this policy. In some cases, your consent may be “implied” i.e., your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.

We will obtain consent when we want to use Personal Information for a new purpose or for a purpose other than those stated at the time of collection in this policy or in the terms and conditions of a specific program, product, service, contest, promotion, or event you signed up for, participated in or purchased. Your consent can be withdrawn at any time, except in limited circumstances, including where withdrawal of consent is restricted by legal or regulatory requirements or as a result of your contractual obligations with us.

If you choose not to provide us with certain Personal Information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the products, services, programs, contests, promotions, events or information that you requested or that could be offered to you.

6. How Do I Change My Privacy Choices?

We want you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences, including, for example:  contacting us directly, changing your browser settings on your device, and/or, where available, using third party unsubscribe functionality.

A. When You Register Or By Contacting Us Directly

You may opt-in to:

·         Receiving email or SMS marketing communications at the time you register for our programs, products or services, enter our contests or promotions or any time thereafter through your online account(s).

You may opt-out of:

·         Receiving email or SMS marketing communications from the sender, by clicking “unsubscribe” within any marketing email you receive, texting “STOP” within any SMS marketing you receive, through your online account (if you have created one).

·         Receiving surveys by following the unsubscribe instructions provided in the email; and

·         Receiving Interest-based advertisements from us and our client advertisers.

Please note the following regarding withdrawal of consent or changes in your privacy preferences:

·         Even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes, in compliance with applicable laws (e.g., for customer service, product information, service or reminder notices, or recalls). We may also need to contact you with questions or information regarding your order, such as order status, shipment, or refunds; and

·         It may take some time for all our records to reflect changes in your preferences (e.g., if you request that you do not want to receive personalized marketing communications from BTRUST, your preference may not be captured for a promotion already in progress).

B. Changing Your Browser Settings On Your Device

·         We use technologies to enhance your customer experience and present offers to you, including interest-based advertisements (see Interest-Based Advertising). For example, technologies such as cookies allow us to recognize when you use or return to our websites, providing you with a more seamless experience. You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features of our websites.

·         Please refer to your browser instructions or help screen to learn more about how to block, delete and manage cookies on your computer or mobile device. You can also use the quick links below, based on the browser type that you are using: Internet Explorer, Google Chrome, Firefox, and Safari.

C. Using Third Party Unsubscribe Functionality

·         We may use third parties (e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behaviour as you visit our websites. You can manage your privacy preferences with respect to certain third parties, such as Google or Facebook, by using the unsubscribe functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our websites and mobile applications.

·         For example, Google Analytics uses cookies to analyze your browsing behaviour on our websites. This information is not provided to us in a personally identifiable format and is collected through your ad settings on your device or browser. If you would like to opt out of Google’s ad settings, please go to www.google.com/settings/ads or use the Google opt out browser add-on located at https://tools.google.com/dlpage/gaoptout.

·         We also may embed links to other websites, including social media websites, on our websites. For more information about social media plug-in protocols, such as “Like” buttons on Twitter, Facebook or Instagram and their impact on your privacy rights, please visit the appropriate social media help centre (e.g., Facebook’s Help Center at https://www.facebook.com/help/).

7. How Do We Protect And Store Personal Information?

We take the security of your Personal Information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. These measures include multi-factor authentication, masking, encryption, logging and monitoring as described below. We store your Personal Information for as long as it is necessary to provide you with our programs, products, and services and for a reasonable time thereafter, or as permitted or required by law.

A. How We Protect Personal Information

To protect your Personal Information, we maintain administrative, technical, and physical safeguards in our stores, pavilions, kiosks, offices, digital properties, and information storage facilities. By having these safeguards, we aim to avoid the loss, misuse, unauthorized access, disclosure, or modification of your Personal Information that we hold. These safeguards also apply when we dispose of or destroy your Personal Information.

For example, where appropriate, we use the following safeguards:

• Multi-Factor Authentication, which is a method of confirming your identity by using more than one way to authenticate you, such as asking for your password and a code that is sent to your email address or phone number;
• Masking, which is the process of obscuring your information so that the structure remains the same, but the content is no longer identifiable;
• Anonymization, which is the process of altering your data so that it can no longer be used to identify you personally;
• Encryption, which is the process of obscuring your information to make it unreadable without the use of a code or a key; and
• Logging and monitoring, which is the process of tracking, recording and monitoring activity related to the access and/or use of your accounts or Personal Information.

We maintain policies and practices which ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:

• Internal policies and procedures that govern our privacy and personal information handling practices, including responding to privacy complaints or inquiries, investigating potential incidents and records management;
• Regular employee privacy and security training; and
• Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate privacy protections and standards, as described above.

B. Where We Keep Personal Information

We use all reasonable safeguards, including contractual requirements with our service providers, to protect your Personal Information wherever it is used or stored. In general, we store, access and use Personal Information in Canada. Some of our service providers may access, process or store your Personal Information outside of your province, territory or Canada in the course of providing their services to us. When we engage a service provider that operates outside of Canada, Personal Information may be stored, processed, accessed or used in another country. In that case, the Personal Information is subject to the law of the jurisdiction in which it is used or stored, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. The jurisdictions where our service providers are currently located in Canada.

 

C. How Long We Keep Personal Information

We will store your Personal Information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your Personal Information will be securely destroyed or anonymized (so the information no longer identifies you).

Please note that if your Personal Information is collected by a third party, it will be retained in accordance with the privacy policies and records retention requirements of that third party.

8. How Are Your Rights in Relation to Your Personal Information?

Under Canadian privacy law, you have the right to request access, correction and deletion of the Personal Information we hold about you subject to any legal restrictions. Upon request, we will respond to your request within a reasonable timeframe, in compliance with applicable laws.

It is your responsibility to provide accurate, correct and complete information. If you notice any errors in your Personal Information or need to update it, please let us know through the steps outlined below.

Some of the Personal Information we hold about you is accessible to you through your online account(s). You can access and update or correct your Personal Information by logging into your account(s) and making updates to your profile information and your preferences.

To access your Personal Information collected by a third party, please contact that third party directly.

9. How Do I Know If There Are Changes To The Privacy Policy?

We may make changes to this policy from time to time. Any changes we make will become effective when we post a modified version of the policy on this webpage. If we make any significant changes to the policy, we will post a notice on our websites. By continuing to participate in our programs, and/or use our services or purchase our products after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements which may apply. If you do not agree to the changes in our policy, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the policy. The “Effective Date” at the top of the policy indicates when it was last updated.