A. Purpose & Scope
What is Personal Information?
“Personal Information” means any information about an identifiable individual, such as your name, address, telephone number, email address, birth date, and includes non-personal information that we link to Personal Information.
Protecting your Privacy Means:
we keep your Personal Information and the business you do with us in strict confidence;
your Personal Information is not sold;
you have control over how we collect, use, and share your Personal Information;
you have access to the Personal Information we have about you; and
we respect your privacy when we market our products and services.
B. 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;
- inform you about products, services, special offers, programs, contests, promotions or events that Holt Renfrew reasonably believes may be of interest to you. We may also automatically enter you in some of our contests and programs. If you are automatically entered in a contest or program, we will let you know.
- create, administer, and maintain customer accounts, process your transactions and returns;
- establish a record of the Personal Information you provide or that we receive about you;
- recommend particular products and services to meet your needs;
- provide ongoing service;
- improve service delivery;
- respond to your questions, enquiries or complaints or verify instructions from you;
- 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;
- avoid spam on our Blog;
- establish your identification;
- protect you and us from error and fraud; and
- where required, co-operate with law enforcement authorities, to comply with a court order or to prevent a breach of any applicable law.
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 prepare and 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, birth date, 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 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;
- in person, by mail, over the telephone, through our websites or in any other direct manner;
- 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;
- Video surveillance: We may collect Personal Information through video surveillance in areas in and around our stores, where applicable, for the protection of our customers, colleagues and assets and to protect against theft, damage to property and fraud;
- 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, www.holtrenfrew.com/men, www.holtsmuse.com and www.ogilvycanada.com;
- Web Beacons: Web beacons are small, graphic images that allow 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 our e-newsletters and blogs 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;
- Through Third Parties: We may receive Personal Information from other sources. For instance, with respect to our Leased Partners’ products, services or programs who also may collect and share with us, your Personal Information;
- Websites, Social Media, Applications and other Electronic Means: We may collect Personal Information electronically, directly from you or through third parties. For example, we may access Personal Information about you when you share information about yourself on our social media platforms and also when you interact with us electronically such as through our websites, blogs and over email; and
- 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.
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 Share Personal Information:
Holt Renfrew does not sell to third parties any Personal Information we collect. Holt Renfrew may share some Personal Information we collect to selected service providers, vendors, Leased Partners and other organizations outside of Holt Renfrew that help Holt Renfrew provide personalized products, services, programs, promotions, contests or events and advertising to you or help us with our business operations. When Holt Renfrew shares Personal Information with any such party, we limit the use of such Personal Information to those purposes requested by us and we require that the party has adequate safeguards for the protection of that Personal Information.
We may share your Personal Information where necessary to protect our interests or in the event of a sale or transfer of all or part of Holt Renfrew. For example, disclosure may be necessary:
- in order to detect or prevent fraud;
- in connection with a merger with another entity;
- to insure or securitize our assets; or
- to engage in another form of corporate or financing transaction.
- In such an event, we will ensure that 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 investigation or transaction.
C. Your Consent
We identify the purpose for which Personal Information will be used typically at or before the time the Personal Information is collected. Unless permitted or required by law, we will not collect, use or share Personal Information without first obtaining your consent.
Your Consent Can Be Express Or Implied.
Express consent can be verbal or written.
You May Withdraw your Consent at Any Time.
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 or regulatory requirements to prevent this. For information on how to proceed, you can call or email our Chief Privacy Officer at 416-960-2860 or email@example.com. 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. It is also important to note that it may take some time for all of our records to reflect changes in your contact and consent preferences. For example, if you request that you do not want to receive personalized marketing communications from Holt Renfrew your preference may not be captured for a promotion that is already in progress.
D. Accessing, Verifying & Amending Your Personal Information
You Can Access and Verify the Accuracy of your Personal Information.
Holt Renfrew provides a right of access and review of Personal Information in accordance with applicable laws, and will endeavour to provide you with the Personal Information requested within a reasonable time.
You can request to verify, update and correct Personal Information, and 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.
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.
We will respond to access requests as required by applicable laws. We may be unable to provide you with access to certain Personal Information, including for example where the Personal Information requested would reveal confidential information or Personal Information about another customer, or if legal or regulatory requirements prohibit providing access to such information. Where information will not or cannot be disclosed, we will provide you with the reasons for non-disclosure.
Holt Renfrew endeavors 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.
If any employee of Holt Renfrew or personnel of our Leased Partners misuses Personal Information, this will be considered 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, www.holtrenfrew.com/men, www.holtsmuse.com and www.ogilvycanada.com, our websites are able to recognize your Internet service provider, but does not identify you as an individual.
We note that in some of our Stores customers can connect to to www.holtrenfrew.com, www.holtrenfrew.com/men, www.holtsmuse.com or www.ogilvycanada.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.
F. Retention & Disposal
We store, access and use Personal Information in Canada. Unless there is a legal or regulatory requirement to keep such information in Canada, Personal Information may also be stored, accessed, or used outside of Canada. For example, when we engage an outside company or service provider, Personal Information may be stored, accessed or used in any country where that company or service provider is located, or from which it provides services, including for example the United States and the United Kingdom. Where Personal Information is located outside of Canada, it is subject to the laws of that jurisdiction.
We keep your Personal 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 Personal 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.
We Monitor our Compliance with the Holt Renfrew Privacy Policies.
We have procedures in place to assist our employees and Leased Partners personnel in the practice of the Holt Renfrew privacy policies and procedures. Our practices will be reviewed on a regular basis and their findings will be reported to the Chief Privacy Officer.
H. 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 Renfrew:
Talk to Us. In most cases completing a PRIVACY INQUIRY AND INFORMATION CHANGE 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 Store.
The Holt Renfrew Chief Privacy Officer Acts on your Behalf. If your concerns have not been resolved to your satisfaction, feel free to contact the Chief Privacy Officer for Holt Renfrew as follows:
Holt Renfrew Chief Privacy Officer
60 Bloor Street West, Suite 300
Toronto, ON M4W 3B8
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.
I. Anti-Spam Policy
Holt Renfrew maintains a strict no-spam policy. If you receive unsolicited email from Holt Renfrew, our vendors, Leased Partners or agents, please notify us at firstname.lastname@example.org. Include the offending email with all the headers intact. Please be aware that it is not uncommon for spammers to hide behind someone else’s email account, as well as use mail servers that they do not own.
Date of Last Update: November 27, 2014