B.A. Robinson Co. Ltd. Customer Privacy Protection Policy

B. A Robinson Co. Ltd. and Robinson Lighting Ltd. (collectively hereinafter referred to as “BAR”), operating as B. A. Robinson, Robinson Lighting and Bath Centre, McDowell Electric Co. Ltd., and B.C. Plumbing Supplies have appointed a Privacy Officer who is responsible for ensuring compliance with the requirements of the Personal Information Protection and Electronic Documents Act (“PIPEDA”). Should you have any questions regarding this policy or concerns with respect to BAR’s compliance with the requirements of PIPEDA, you should contact BAR’s Privacy Officer, in writing, as follows:

B.A. Robinson Co. Ltd. or Robinson Lighting Ltd., Attention: Privacy Officer
619 Berry Street
Winnipeg, Manitoba R3H 0S2
Facsimile: (204) 775-7440

1. Accountability

BAR respects your privacy and values your business. This Privacy Policy describes the types of personal information BAR collects, how it may use that information and with whom it may share it. This Privacy Policy also describes the measures that BAR takes to protect the security of the information and, in addition, it indicates how you can contact BAR regarding our privacy practices.Please note that BAR’s Privacy Officer, while responsible for BAR’s compliance with PIPEDA, will not necessarily be responsible for the day-to-day collection and processing of personal information since his or her duties may be delegated to other employees of BAR. If BAR transfers personal information to third parties for processing or other purposes related to its operations it shall use contractual or other means to provide a comparable measure of protection while the information is in the possession of such third parties.Additionally, so that BAR may ensure its compliance with PIPEDA, it has implemented practices to give effect to PIPEDA, including, but not limited to, protection of personal information in the custody or control of BAR, educating staff members regarding privacy responsibilities, developing systems to deal with inquiries and/or complaints, and developing explanatory materials regarding its personal information practices.

2. Identifying Purpose of Collection

When you request information about products, services and promotions or make a purchase, either by contacting BAR directly or online you will be required to provide certain personal information to complete your transaction. Depending upon the transaction, this will include name, address, telephone number and may include credit card number and expiry date.The personal information collected by BAR through its website is used only for the following purposes:

  1. settlement of account receivable requirements including but not limited to the payment of invoices;
  2. account information for our Partners Program
  3. updating of accounts receivable filing and information related to the our accounts receivable function.

Cookies

A cookie is a small non-executable file that is stored on your hard drive for the purpose of identifying your computer. While it is possible to make use of BAR’s website by having your browser’s Internet security set such that it will not accept cookies, your online experience may be greatly reduced.BAR uses both session cookies and permanent cookies at barobinson.com/ca, rlrbc.com/ca, , bcplmg.com/ca and mcdowellelectric.com/ca. Session cookies are active only during the period you are logged on to the above noted websites and are removed when you leave. They help us track the sections of the website that you use so that we can improve the design of our website.Permanent cookies remain on your hard drive until you remove them through your browser’s Internet security settings. Permanent cookies are used to store user preferences such as preferred language and thus eliminate your having to make the same entries on each visit.

3. Consent

When you request information regarding BAR’s products, services and promotions or make purchases on line, the fact of your doing so provides BAR with your consent to use your personal information to fulfill your request and/or order. Additionally, under the circumstances set out in Section 7 of PIPEDA, BAR is not required to obtain acknowledgment or consent to the collection, use or disclosure of your personal information. These circumstances include, but are not limited to, disclosure to a lawyer representing BAR, collection of a debt, compliance with a subpoena, warrant or other court order, or otherwise as required by law.If you opt in to one or more of BAR’s email offers you are consenting to allow BAR to contact you regarding those offers. You may withdraw your consent at any time simply by changing your profile information or by following the instructions on how to “unsubscribe” contained in all emails sent to you by BAR.BAR will seek your further consents to any additional uses for which it has not obtained your consent previously.

4. Limiting Collection

BAR will limit the collection of personal information to that which is necessary to fulfill the purpose for which it was collected and as disclosed by it. BAR shall collect personal information directly from you and may collect such information from other sources including, but not limited to, credit bureaus.

5. Limiting Use, Disclosure and Retention

BAR will not use or disclose your personal information for purposes other than those for which it was collected without your explicit consent or as required by law.Customer information is retained for as long as necessary to fulfill the purposes for which it was collected and for any appropriate time thereafter including a sufficient period time following to permit you to ask any questions regarding its use.BAR reserves the right to transfer any information that it has about you in the event that it sells or transfers all or a portion of its business or assets. If the business is transferred, BAR will provide you with an opportunity to tell it that you would prefer that information about you not be transferred. In the event of such a transfer, BAR will use reasonable efforts to try to ensure that the transferee uses personal information about you in a manner that is consistent with this Privacy Policy.

6. Accuracy of Information

When you contact BAR directly to request information about its products, services or promotions or use barobinson.com/ca, rlrbc.com/ca, bcplmg.com/ca and mcdowellelectric.com/ca. you can ensure that the personal information it is provided and thereafter holds is accurate and up to date. If personal information that you supply should change, for example, if your telephone number changes, you can contact BAR and provide it with updated information. BAR shall update personal information about its customers as required to meet the purposes for which it is collected or upon receiving a request to do so from a customer.

7. Safeguards

BAR maintains administrative, technical and physical safeguards to protect against unauthorized disclosure, use, alteration and destruction of the personal information in its possession.Administratively, BAR has limited the number of its employees who have access to personal information of customers and has made such employees aware of the importance of maintaining the confidentiality of its customer’s personal information. Additionally, and as already noted, BAR shall, where appropriate, protect personal information disclosed by it to third parties through contractual arrangements.With respect to technical measures employed by BAR, personal information collected through its website is encrypted as it travels over the Internet. Depending on a customer’s web browser you may see a secure webpage indicator, for example a closed lock in the lower right hand corner of the Internet Explorer browser.The use of Secure Socket Layer protocol (SSL) allows all personal information such as your credit card number, to be encrypted as it travels from your computer to BAR. Once received, the information is unencrypted and processed in the same way as a credit card transaction placed via the telephone or in person.Internally within BAR’s computer system, personal information held in electronic form is password protected so as to limit the number of employees who may access same.Finally, BAR has taken physical measures to ensure that personal information of customers that is held by it in other than electronic form is kept in secure locations with access restricted to a limited number of employees.

8. Openness

BAR’s privacy practices are as outlined within this Privacy Policy. Should you have any questions or comments you may contact BAR’s Privacy Officer as indicated at the introduction to this Policy.

9. Access to Personal Information

With certain limited exceptions as provided in PIPEDA, you have a right to access your personal information held by BAR. If you want access to other personal information held by BAR you may contact our Privacy Officer in writing as indicated at the introduction to this Privacy Policy.BAR shall make your personal information available in understandable form and within the time period stipulated by PIPEDA. If you demonstrate that the personal information held by BAR is not accurate or incomplete, BAR will amend its records as required.

10. Challenging Compliance

If you have any concerns regarding BAR’s compliance with the 10 principles of PIPEDA you may address those concerns to BAR’s Privacy Officer as indicated at the introduction to this Privacy Policy. Complaints concerning BAR’s compliance with PIPEDA are taken seriously and all complaints are investigated. BAR may seek external advice where appropriate before providing a final response to any complaint received.If a complaint is determined to be justified, BAR shall undertake appropriate remedial measures, which may include, where necessary, amendment of its policies and procedures.Changes to the Privacy Policy

This policy takes effect on November 1, 2007. BAR reserves the right to modify this Privacy Policy at any time, so please review it frequently. If BAR makes material changes to this policy it will notify you on its homepage and other places it deems appropriate so that you are aware of what information BAR collects, how it is used, and under what circumstances, if any, it will be disclosed.

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