Privacy Policy

ePawn Privacy Statement (updated on August 9, 2011)

 

The purpose of this Privacy Statement is to inform you about the types of personal information ePawn Corporation (Ltd.). (as follows, “ePawn”, “we” or “us”) collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure and how you may correct that information.

We are proud to demonstrate our commitment to your privacy by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.
We will treat personal information in a manner consistent with the version of the Privacy Statement under which it was collected and our Privacy Policy, unless we have your consent to treat it differently.

This Privacy Statement applies to any personal information we collect or receive about you, from any source, including through our websites and other online platforms (the “Sites”). We encourage you to read this Privacy Statement before providing us with any personal information and before using any of the Sites. By providing us with any personal information or using any of the Sites, you are signifying that you agree with all of the terms of this Privacy Statement, so please do not do so if you disagree with any part of this Privacy Statement.

  1. Collection of Personal Information
    1. To which companies does this Privacy Statement apply? This Privacy Statement applies to the collection, use and disclosure of personal information by ePawn Ltd.
    2. What is personal information? Personal information is any factual or subjective information about an identifiable individual. Your personal information may include but is not limited to your name, mailing address, phone numbers, gender, email address, identification numbers, etc. Personal Information, however, does not include your name, business title or business address and business telephone number in your capacity as an employee of an organization.
    3. How do we collect your personal information? We will always collect your personal information by fair and lawful means. For example, you may provide your personal information when you complete a contest ballot form, submit a promotional product request form or contact consumer service. You may also provide your personal information when you use one of our Sites, including by creating an account, entering a contest, signing up for email communications or participating in a survey. We sometimes collect personal information from you through third party service providers, where we have obtained your consent to do so or as otherwise permitted by law.We may also collect your demographic data, such as your gender and postal code, when you provide this information to us. Demographic data may be used to tailor your experience on the Sites and the communications you receive from us. On occasion, aggregate information that does not identify any particular user may be compiled and shared with our affiliates and other third parties as described in Section III below.
    4. How do we use technology to collect information through the Sites? The Sites collect some information about you using technology, so it may not be readily apparent to you that it is being collected. The Sites use information collected through technology to make our Sites more interesting and useful to you. As part of these processes, your personal information may be stored and processed outside of Canada. We will not disclose your personal information to anyone else outside the ePawn zone without your consent. What about cookies? “Cookies” are data files that a website sends to your computer while you are viewing the site. These data files include information that allows a website to remember important information that will make your use of the website more efficient and useful to you. Cookies do not cause damage to your computer systems or files, and only the website that transferred a particular cookie to you can read, modify or delete such cookie. How does ePawn use cookies? Our Sites use encrypted and non-encrypted cookies for a variety of purposes. We may use cookie technology and IP addresses to obtain non-personal information from our on-line visitors and also to provide registered visitors with the best possible personalized on-line experience. For example, as part of the log-in process, our Sites may use persistent cookies when you give us permission to do so. Persistent cookies are cookies stored on your computer. They allow us, with your permission, to remember information about you, such as your log-in information, so that we may enhance your experience the next time you visit the Site. You must give your permission to allow our Sites to set persistent cookies. You may opt-out of the use of persistent cookies at any time. We may also use flash cookies, also known as “local shared objects”, on our Sites during the log-in process. Flash cookies are small files similar to browser cookies and are used to remember a website’s settings in order to personalize the look and feel of the site. Flash cookies only collect data in the aggregate. Our Sites’ log-in processes may also use session cookies, if you choose to register with a Site. Session cookies enable the Site to recognize your log-on credentials, and enhance your browsing experience on the Site. Some uses of cookies in connection with our Sites may be under the control of unaffiliated entities that ePawn retains for the management of certain programs and the fulfillment of specific visitor/customer requests. ePawn requires these entities to confine their use of cookies to the uses permitted by this Privacy Statement, but ePawn cannot be responsible for third party uses of cookies. What if I don’t want cookies? If you don’t want to use cookies with our Sites, there are simple procedures in most browsers that allow you to delete existing cookies, to automatically decline cookies or to be given the choice of declining or accepting the transfer of particular cookies to your computer. Please refer to your browser instructions or help screen to learn more about these functions. YOU SHOULD NOTE, HOWEVER, THAT DECLINING COOKIES MAY MAKE IT DIFFICULT OR IMPOSSIBLE FOR YOU TO USE SOME PORTIONS OF OUR SITES. What about other technologies? Our Sites may also use “pixel tags”, “web beacons”, “clear GIFs” or similar means (collectively, “Pixel Tags”) to compile aggregate statistics about Site usage and response rates. Pixel Tags allow us to count users who have visited certain pages of our Sites, to deliver advertisements for goods and services that may be of interest to you and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened. Additionally, ePawn may collect “referrers” information, IP addresses and various environmental variables through our Sites.
      • A “referrer” is information the web browser passes along to our web servers that references the URL from which you came.
      • The “IP address” is a number used by computers on the network to identify your computer so that data can be transmitted to you. An IP address is often associated with the place from which you enter the Internet like your Internet Service Provider (ISP), your company or your university. This information is not personally identifiable.
      • “Environmental variables” include, among other things, the domain from which you access the Internet, the time you accessed this site, the type of web browsers and operating system or platform used, the Internet address of the website you left to visit our Sites, the names of the pages you visit while at our Sites and the Internet address of the website you then visit. This information is collected for ePawn ’s internal use, such as to enhance website security, to detect broad demographic trends, to assist ePawn in providing content tailored to your interests and to otherwise enhance your experience on the Sites. This information may also be shared with third parties on an aggregate and non-personally identifiable basis. We may use both personal information and non-personal information, individually or together, to improve our marketing and promotional efforts, improve our products and services, better understand customer interests and preferences, and provide you with relevant information. We may enhance or merge personal information that you provide with data obtained from third parties.
  2. Use of Personal Information
    1. How do we use your personal information? Whenever we collect your personal information, we will identify the purposes for which we will use that information and we will obtain your consent to such use. We may collect your personal information for a variety of reasons, including: sending you information and communications; responding to product inquiries and other requests; conducting contests and promotions (including sending prizes to winners directly or through third parties acting on our behalf); processing transactions; optimizing your experience on our Sites; addressing product injury claims; and for internal purposes such as analyzing and managing our business. We may also use your personal information as otherwise permitted by law.
    2. When and how do we obtain your consent? We obtain your consent prior to collecting, using or disclosing your personal information for any purpose. You may provide your consent to us either orally or in writing. For example, when you submit a contest ballot form to our redemption house, you provide your consent to allow the redemption house to disclose the information in the ballot form to us so that we may identify you as a contest winner. From time to time, we may collect, utilize or disclose your personal information based on your consent and as permitted by law.
    3. How long will we utilize, disclose or retain your personal information? We may keep a record of your personal information, correspondence or comments, in a file specific to you. We will utilize, disclose or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. We have established minimum and maximum retention periods and procedures for maintaining and destroying your personal information.
    4. What about User Generated Content? From time to time, we may receive content from consumers as part of contests, promotions and other functions of our Sites (“User Generated Content” or “UGC”). Any UGC you submit may be publicly displayed, including on our Sites, and is subject to any terms and conditions communicated to you as part of the submission process. Please remember that any information you disclose in connection with a UGC submission may become public information and you should exercise caution when deciding to disclose your personal, financial or other information in a submission. ePawn cannot prevent such information from being used in a manner that may violate this Privacy Statement, the law or your personal privacy and safety and ePawn is not responsible for the results of such postings.
    5. ePawn Communications Through our Sites and various offline means, you may sign up or opt-in to receive communications from ePawn . If you do not opt-in, ePawn will not send you any communications, including promotional offers. Each communication sent to you by ePawn contains an “unsubscribe” link or other unsubscribe mechanism, allowing you to opt-out at any time. If you opt-in to receive communications from multiple brands within the ePawn , and subsequently wish to opt-out, you may need to opt-out individually from each of the brands you elected to receive communications from. See Section IV below for further information on modifying the personal information we have for you, including communication preferences.
  3. Disclosure of Personal Information to Third Parties As described below, we will never share private information with any third parties. Exception (v) is local authorities such as law enforcement or regulatory agency or other legal process. Any information you share with ePawn is completely confidential and will never be disclosed with any other parties (v).
    1. When do we disclose personal information to third parties? Third Parties. We will never share personal information with other companies (third parties) outside the ePawn family of companies: (i) unless permitted by law; (ii) in the event of violation of law, fraud, criminal activities (iii) where we determine that disclosure of specific information is necessary to comply with the request of a local authorities such as law enforcement or regulatory agency or other legal process; or (iv) to protect the interests or safety of ePawn , our customers and consumers and other users of our Sites.
    2. How do we ensure the privacy of your personal information when dealing with local authorities? We ensure that local authorities that are engaged to perform necessary action on our behalf and are provided with personal information are required by contract to observe the intent of this Privacy Statement and our Privacy Policy.
  4. Openness, Access and Security
    1. How can you review your personal information that we have collected, utilized or disclosed? ePawn has a variety of convenient methods available that allow you to review, correct, update or otherwise modify information previously collected from you, including communication preferences. You may:
      • modify your information on your account profile page on the applicable Site
      • use the Contact Us form on the applicable Site
      • call 1-905-884-8338 (Monday – Friday, 10:00 am to 6:00 pm EST)
      • write us at ePawn Ltd., 636 Edward Avenue, Unit 1A; Richmond Hill, Ontario, L4C 0V4
      • We will make available to you any specific personal information of yours that we have collected, utilized or disclosed, upon your request, to the extent permitted by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes.
    2. How do you know that the personal information we have for you is accurate? We will ensure that your personal information is kept as accurate, complete and up-to-date as possible. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with updates to your personal information, when required.
    3. What if the personal information we have for you is inaccurate? As described in Section IV.A above, you can, at any time, contact us to review, correct, update or otherwise modify the personal information we have for you. In each such case, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personal information removed from our database. If you successfully demonstrate that the personal information we have for you is inaccurate or incomplete, we will amend our records of your personal information as required. Note that despite any request for a change to or removal of your personal information, we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. We may make efforts to transmit any amended information to local authorities having access to your personal information. However, we are not responsible for informing third parties with whom we have previously shared your personal information of any changes requested pursuant to this Section or for removing information from or causing information to be removed from the databases or records of such entities.
    4. How fast will we respond to your requests? Please note that requests for changes to your personal information, even those submitted through our Sites, may not be effective immediately. We will attempt to respond to any requests regarding personal information as soon as reasonably possible, and in any event not later than 30 days after receipt of each such request. We will advise you in writing if we cannot respond to any of your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.
    5. Are there any costs to you for requesting information on your personal information or on our Privacy Policy?We will not assess any costs to you for access to your personal information or on our Privacy Policy without first providing you with an estimate of the approximate costs, if any. You may withdraw your request for access to information by notifying us within the 30 day notice period disclosed on the estimate. If you do not notify us within such 30 day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within 30 days. If after the expiry of this 30 day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.
    6. How do we know that it is really you requesting your personal information? We may request that you provide us with sufficient identification before granting you access to information regarding the existence, use or disclosure of your personal information. Any such identification information shall be used only for this purpose.
    7. What safeguards have we implemented to protect your personal information? We have implemented physical, organizational, contractual and technological security measures to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your personal information are those with a business “need-to-know” or whose duties reasonably require access to such information.
    8. What type of security do we provide on our Sites? The importance of the security of all personal information collected through our Sites is of utmost importance to us. We have taken reasonable technical, contractual, administrative and physical security steps to protect the personal information collected from you through the Sites, consistent with standard industry practice and the sensitivity of the personal information collected. For example, if and when you provide credit card information, we use secure socket layer (SSL) encryption to protect it. These security measures are periodically reviewed. However, there are some things that users of our Sites can do to help protect the security of their personal information as well. For instance, no user should ever give out their user name password. Also, every user should sign out of their internet account and close their browser window each time they finish using the internet so that other people using the same computer will not have access to their information.
    9. Links to Other Sites. Our Sites may contain links to other websites that are not operated by ePawn. EPAWN IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OR THE CONTENT OF SUCH OTHER WEBSITES, INCLUDING WEBSITES OPERATED BY AFFILIATED ENTITIES. We provide such links only as a convenience and the inclusion of a link on any of our Sites does not imply endorsement of the linked to website by ePawn . If you provide any personal information through any such third party websites, your transaction will occur on such third party website (and not on our Sites) and the personal information you provide will be collected by and controlled by the privacy policy of that third party. ePawn recommends that you review the privacy policies of third party websites arrived at from links on our Sites before using those websites.
    10. Whom do I contact with questions or concerns about this Privacy Statement? If you need further assistance, please contact the ePawn Privacy Officer either by writing to us at ePawn Ltd., 636 Edward Avenue, unit 1; Richmond Hill, Ontario, L4C 0V4, by telephone at 1-416-244-2476 or by contacting us via the Contact Us page at www.ePawn .caPrivacy Statement Updates. ePawn reserves the right to make changes in this Privacy Statement. Such changes will take effect immediately upon posting. For your convenience, the last revised date of the current Privacy Statement will be posted at the top of this page. By continuing to interact with us following such changes, including by using our Sites, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Statement, please do not continue using our Sites.
  5. Governing Law This Privacy Statement is governed by, and interpreted and enforced in accordance with, the laws in force in the Province of Ontario and the federal laws of Canada (excluding any conflict of laws, rule or principle which might refer such interpretation to the laws of another jurisdiction).
0