City Electric Global Privacy Notice

1. Scope

This Privacy Notice describes how City Electric Group Limited and its wholly owned subsidiaries including without limitation, City Electric Supply Company (collectively, “City Electric,” or “Company” “we,” “us,” or “our”) collect, use, disclose and otherwise process information that identifies you or could reasonably be used to identify you (“personal data” or “personal information”). Unless otherwise specified, City Electric Supply Company is the controller of, and responsible for the personal data we process under this Privacy Notice.

This Privacy Notice applies to personal data processed by us on websites where we offer information about our business and sell our products (the “Sites”), mobile or web-based applications that we may offer in conjunction with our business (any, an “App”), and other online or offline offerings that we may make available to business consumers (collectively, the “Services”) that link to this Privacy Notice.

This Privacy Notice may supplement or be superseded by other privacy notices that may relate to specific jurisdictions, products, or relationships you have with us. For example, if you work for City Electric or apply for a job with us, please see our Worker and Applicant Privacy Notice. For residents of the UK, EU, Canada and other jurisdictions and certain US states with comprehensive privacy laws, additional disclosures about the information we collect is contained in the Supplemental Disclosures below. Further, if you are eligible and elect to participate in certain promotional activities we may offer or sponsor from time to time, all personal data, including any sensitive or special category data that we may collect will described at the time you enroll and be processed in accordance with the terms of the explicit, informed consent you provide when you elect to enroll or enter.

2. Information We Collect

The categories of personal data we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below. If we are required by applicable law or by the terms of a contract to collect your personal data and you fail to provide the necessary information to us, we may not be able to provide you with Services you requested or otherwise perform under our contract with you.

• Identifiers. We may collect identifying and contact information such as your first and last name, email address, address, and phone number.
• Demographic Information such as your age level (so that we can ensure you are the appropriate legal age to receive communications from us or to enter a contest/survey) or gender (to allow us to better communicate with you).
• Account Information. We collect personal data when you register and create an account or Trade Account on our Sites, such as residential address including zip or postal code to determine eligibility for delivery, name, email address, username and password, telephone number, and any other details in connection with your account.
• Purchases and Payment Information. We may collect personal data and details associated with your commercial interactions with us, such as your transaction history and record of services or products obtained from us, including on behalf of an organization you are affiliated with. For example, we will record the details of the products you ordered, the location of a retail outlet you transacted with, or other information associated with a transaction or series of transactions. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
• Customer Service and Feedback. We may collect personal data, such as email address, phone number, or mailing address when you request information about our Services, register for any informational communications, marketing and promotional correspondence, request customer or technical support, or otherwise communicate with us.
• Promotional Activities. We may collect personal data from you if you are registered user or account holder of our Site(s) or App(s) and you elect to participate in promotions we offer from time to time. We may also identify eligible adults to participate in other commercial programs if and as we may develop and offer them from time to time (any, an “Optional Program”) If you elect to participate in any of our Optional Programs, we may collect personal data from you to verify your eligibility and or to support your participation in the Optional Program. Any promotions we offer will be conducted and managed in compliance with applicable law, which may dictate the type of personal data we collect and whether and how we disclose it.
• Conferences, Trade Shows, and Other Events. We may collect personal data from individuals when we attend or host conferences, trade shows, and other events.
• Business Contacts. We may collect personal data from individuals and third parties to conduct due diligence or otherwise assess and pursue potential business opportunities.
• Social Media Account Information. If you link or communicate with us via a third-party social media account, we may collect information you have publicly shared on your account.
• Device and Internet Browsing Information. We may collect information about the devices you use to access our Services, including technical information about your device and network, such as hardware model, operating system version, your internet protocol (IP) address, user settings, MAC address, mobile carrier and other unique mobile identifiers, browser or device information, location information (including approximate location derived from IP address), and internet service provider. We may also collect information about your activity on our Services and your interactions with our ads and communications, such as the routes by which you access our Services along with access dates and times, browsing behavior such as pages viewed, links clicked, information about your activity on a specific page(s) and other information about how you use our Services.
• Location Information. We may collect location information through our Sites, Apps or using technology used in some of our retail locations using geolocation and technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. For most mobile devices and computer systems, you can disable the collection of this information by using the device or web-browser settings. If you have any questions about how to prevent your devices from sharing their locations, we recommend you contact your mobile-device service provider, the device manufacturer, or your web-browser provider. Some of our Services may not work properly without information about your location.
• Online Technologies. We as well as third parties that provide content, analytics, or other functionalities in relation to our Services, may use technologies such as cookies, web beacons and similar tools (“Technologies”) to automatically collect information through your use of our Services and distinguish you from other users of the Services. We may use Technologies in various ways, as described by the following categories:
  • Essential/Operationally Necessary. These Technologies are essential to our ability to offer our Services and include technologies that allow you access to our Services, applications, and enable tools that we use to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of embedded functionalities or features of our Services.
  • Performance-Related Technologies. These Technologies help us assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services.
  • Functionality-Related Technologies. These Technologies allow us to operate our Services and offer enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past viewing activities.
  • Analytics. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services.
  • Advertising. These Technologies may be set by us or through our Sites by our advertising partners. They may be used by those companies to build a profile of your interests including cross-device tracking, to deliver content and show you relevant advertisements on other sites by uniquely identifying your browser and internet device. If you do not allow these Technologies, you will still experience advertising, but the advertising will not be customized.
• Social Media Platforms. We maintain social media accounts that contain marketing as well as informational, non-promotional content such as job postings, and press releases on corporate developments. If you visit one of our social media accounts, the social media site, like any other third-party site, may collect personal data. Your interactions with these platforms are governed by the privacy policy of the company providing it.
• Fraud and Abuse Prevention Providers. We may use third-party services to protect our Sites from fraud and abuse. For example, we may use Google’s reCAPTCHA technology to evaluate various device-and-user based analytics to estimate whether the activity is from an automated program (i.e. a “bot”) or a human. You can learn more about how data processed by reCAPTCHA is used by reviewing Google’s privacy policy.

3. How We Collect Information

There are several ways we may obtain information about you. We collect information that you elect to provide to us when using our Services and when you otherwise interact with us, such as through our Apps and customer service channels, that we collect automatically when you use our Services, and that we receive from third parties.

• We Collect Information from You Directly. We collect information when you use our Services or otherwise interact with us. This includes registering to use our Services and creating an account on a Site, placing an order, providing a review, registering, signing up for communications, or participating in surveys or promotional programs we may offer.
• We Collect Information Automatically When You Use Our Services. We as well as third parties that provide content, analytics, or other functionality on our Services, may use cookies, pixel tags, and other technologies (collectively, “Technologies”) to automatically collect information through your use of our Services. This includes information about your equipment, browsing actions and patterns.
• We Collect personal data from Third-Party Services and Other Sources. Where permitted by law, we may obtain personal data about you from third-party services and organizations, from other individuals or from publicly available sources. Further, if you access our Services through a third-party application, such as a social networking site, we may collect personal data about you from that third-party application that you have made available via your privacy settings. We may also use identity and contact data that we receive from our marketing partners, to help us more effectively target our marketing campaigns.

4. How We Use Information

We will only use your personal data for lawful purposes. Specifically, we may use your personal data for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below. More information about the legal basis for each of these purposes under applicable data protection laws is set forth in our Supplemental Disclosures.

We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose as specified in applicable data protection laws. If we need to use your personal data for a purpose that we have not specified in this Privacy Notice, we will notify you where we are required by applicable data protection laws to do so and we will explain the legal basis which allows us to do so, or seek your consent, as required.

• We Use Information to Provide our Services. We use personal data and other information to provide our Services, including by:
  • Verifying your identity and eligibility to establish a trade account, and otherwise, register you as a new customer on the Site(s) or App(s) and transact with us;
  • Confirming and fulfilling your purchases;
  • Managing our relationship with you, your information and account;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Answering requests for customer or technical support;
  • Communicating with you about your account, activities on our Services, and policy changes, and
  • Processing your financial information and other payment methods on our Sites.
• Administrative, Regulatory and Compliance Purposes. We may use your personal data for various administrative, regulatory and compliance purposes, such as:
  • Authenticating and verifying identity, for example in conjunction with honoring requests to exercise privacy rights under applicable law;
  • Providing information required to meet our compliance obligations or commitments;
  • Detecting misuse or improper trade or dealing with respect to our products, security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and investigating, educating and or prosecuting those responsible for that activity;
  • Auditing relating to interactions, transactions, and other compliance activities;
  • Measuring interest and engagement in our Services, including the use of data analytics to improve our website, products, app and customer experience;
  • Improving, ensuring the safety of, and operating quality controls pertaining to, upgrading, or enhancing our devices and Services;
  • Debugging to identify and repair errors with our products and Services;
  • Delivering relevant website content and advertisements to you and measuring and understanding the effectiveness of the advertising we serve to you;
  • Sharing personal data with third parties we’ve engaged as service providers as necessary to provide the Services;
  • Enforcing our agreements and policies, including without limitation, violations of our commercial terms with distributors or retailers, our Terms & Conditions, and this Privacy Notice, including notifying you of changes to this Privacy Notice;
  • Carrying out activities that are required to comply with our legal obligations (including obligations imposed by regulatory decree, court order, or legal settlement), or when we believe it is necessary to investigate, prevent, or take action regarding underage use or purchase of our products, illegal activities, suspected fraud and/or counterfeit, situations involving potential threats to the safety of any person;
  • Providing relevant or requested evidence in litigation in which we are involved, and
  • For other legitimate business purposes as permitted by law.
• Marketing and Advertising. We may use personal data to market and advertise our business, products and Services as permitted by applicable law. For example, we use Technologies to engage in online marketing activities as described in this Privacy Notice and may make product recommendations or offers available to current account holders based on past purchase history or other relevant information.
• De-identified and Aggregated Information. We may use personal data to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create. We use this de-identified or aggregated data for the purposes outlined in this Privacy Notice and afford it appropriate protections as required by applicable data protection and other laws.
• Other Purposes. We may also use your personal data for other purposes with your consent, as requested by you or as required or permitted by applicable law.

5. How We Disclose Information

We may disclose your personal data to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

We may also disclose your information with third parties as required, appropriate or otherwise permitted by law.

We do not allow our third-party service providers that process your personal data on our behalf to use your personal data for their own marketing or any other purposes, and we only permit them to process your personal data pursuant to the terms of written contracts for specified purposes and in accordance with our instructions.

• Disclosures to Provide our Services. The categories of third parties with whom we may share your personal data are described below.
  • Service Providers. We may disclose your personal data to our third-party service providers and vendors that assist us with the provision of our Services. Service providers include, for example, internet service providers, data analytics providers and advertising partners, operating systems and providers, and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
  • Business Partners. We may disclose your personal data to our business partners to provide you with a product or service you have requested. This includes, for example, delivery service providers that we use to fulfill orders made on our Site.
  • Affiliates. We may disclose your personal data to our company affiliates (other companies and brands owned, controlled, or under common ownership with The Company) or administrative or regulatory compliance purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
  • Social Networks. Your personal data may be disclosed to social networks if you visit our corporate social media accounts by clicking a social media widget from our Sites (e.g., Facebook, Instagram, LinkedIn, etc.).
  • Advertising Partners. We work with third party companies that support our advertising and marketing efforts, including to serve interest-based advertisements across the internet; track and categorize your activity, interests and device(s) used over time on our Sites and Apps, and on third-party websites and mobile applications; and research and analytics efforts, including to better understand how use our Sites and Apps to improve those technologies and optimize your experience and interactions with us. Our third-party advertising or analytics partners may include, for example Google and Meta. For more information about how Google uses your personal data (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google’s Privacy Policy. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please go to the Facebook ad preferences page while logged in to your Facebook account.
• Disclosures to Protect Us or Others. The categories of third parties with whom we may share your personal data are described below.
  • Government Entities and Parties to Litigation. We may disclose your personal data to government entities or in the context of private or public litigation, for our administrative purposes, to meet our statutory, regulatory, or other compliance-related obligations, or to respond to a legal inquiry or mount a defense to an allegation in a legal or regulatory context.
  • External Parties to Comply with Legal Process or in the Public Interest. We may access and disclose personal data or information we can associate with you to external parties if we believe in good faith that doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; to protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
• Disclosures in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and contract.

6. Your Privacy Choices

The privacy choices you have about your personal data are determined by your specific circumstances, the context, and applicable law, and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications.
• Text Messages. If you opt in to receive messages via text, you may manage the text-based messages you receive from us or opt out of further SMS communications at any time by following the instructions in any SMS message you receive. You can also contact us for help at any time if you receive unwanted SMS messages. We will not sell or share your phone number or mobile information to third parties for promotional or marketing purposes.
• Phone calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call, or you may Contact us at any time as set forth below. We will not sell or share your phone number or mobile information to third parties for promotional or marketing purposes.
• App Deletion. If you have installed the CES Picks App or any other App offered by the Company on your mobile device, you may delete it and all its data by following the prompts on your device.
• Technologies. You can control our use of certain Technologies in the following ways:
  • Cookie Controls. You may decline all or select the types of non-essential Technologies that apply to your use of our Services by managing your preferences using the Cookie Settings link, or similar feature, available on our Sites.
  • Business Partners. You may also stop or restrict the placement of certain Technologies in your browser or remove them by adjusting your preferences as your browser permits. These tools are generally available in the help section of browsers. You can also use the quick links, based on the browser type that you are using: Edge, Google Chrome, Firefox, and Safari.
  • Mobile Device Controls. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. Please note that cookie-based opt-outs may not stop all mobile tracking, such as tracking done on mobile applications.
  • Ad Industry Opt-outs. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

7. Your Privacy Rights

In accordance with applicable law, you may have various privacy rights, as outlined below. If you would like to exercise any of these rights, please Contact Us at any time as set forth below. We will process such requests in accordance with applicable laws and will not discriminate or retaliate against you for the exercise of any privacy rights granted to you by applicable law. Depending on your jurisdiction, you may also designate an authorized agent to exercise a privacy right or rights on your behalf. We may ask authorized agents to submit proof of their authority to make certain requests (such as deletion or access requests), on your behalf. In some cases, we may be required to contact the individual who is the subject of the request to verify their identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of an individual, please Contact Us.

• Access and Obtain a Copy of your personal data, including: (i) confirming whether and how we are processing your personal data; (ii) obtaining access to or a copy of your personal data; and (iii) receiving an electronic copy of personal data that you have provided to us; (iv) for automated information where our processing is based on consent or the performance of a contract with you, or (v) data portability (asking us to send that information to another company in a structured, commonly used, and machine-readable format);
• Request Correction of your personal data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal data;
• Request Deletion of your personal data, which enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, when you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• Request Restriction of or Object to our processing of your personal data where the processing of your personal data: (i) is based on our legitimate interest for direct marketing purposes; (ii) involves processing or sharing of your sensitive personal data for certain non-essential purposes, or in contexts that require your consent; and (iii) for profiling in furtherance of decisions that produce legal or similarly significant effects that concern you;
• Opt-Out of “Sale” or “Sharing” Although we do not “sell” your personal information as the term “sale” is typically understood, we may “sell” or “share” information with our advertising and analytics partners to help us understand how visitors use our Services and to serve you ads on and off our Sites and Apps. Where applicable, we will offer you a choice about whether to accept or opt-out of certain Tracking Technologies, the use of which may constitute a “sale” or “share” of personal information under certain state privacy laws in the United States.
• Withdraw your Consent to our processing of your personal data. Where our processing is based on your consent or subject to your objection, please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal. See “Opt-out of ‘Sale’ and ‘Sharing’” in our Notice at Collection and US State Privacy Notice.
• Appeal. You may have the right to appeal our decision or response to your request. To exercise your right to appeal, you can submit an appeal request using the same method used to submit your original request, including by Contacting Us at any time as set forth below.
• Lodge a Complaint. While we are always willing and eager to listen and respond to your concerns about this Notice or our data practices, at any time you have the right to lodge a complaint with the data protection authority or other regulatory body in charge of enforcing data protection laws in your jurisdiction.

8. Cookies

9. Information Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal data.

10. Third Party Links and Content

Our Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal data to third-party websites or applications is at your own risk.

11. International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States, which jurisdictions may have data protection laws that are different from the laws where you live. We will safeguard your information consistent with the requirements of applicable laws.

12. Information Retention

We store the personal data we collect as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data, in each case in line with our data retention policies. For example, we do not retain the last several digits of your government ID if we have collected them to verify your identity, and any photo you submit in conjunction with the age verification process is deleted after the minimum period required to enable us to meet our legal obligations.

13. Children

Protecting underage individuals is important to us. If you are a parent or guardian and believe your underage child has created an account or otherwise provided personal data through our Services and wish to have that information modified or deleted, Contact Us at any time as set out below. If we become aware that an underage individual has provided us with personal data in violation of our policies, compliance obligations or applicable law, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the minor’s account if applicable.

14. Changes to Privacy Policy

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law.

15. Contact Us

If you have questions about our privacy practices or this Privacy Notice, please contact us at City Electric Supply Pty Ltd, Unit 4 / 1 Reliance Drive, Tuggerah, NSW, 2259 or call us at 02 4367 1190. To exercise your rights as detailed in this Privacy Notice, please contact us at [email protected] for enquiries.

16. Supplemental Disclosures for Specific Jurisdictions

• Notice at Collection and US State Privacy Law Notice. Some US states have privacy laws that require specific disclosures and afford residents of those states with additional privacy rights. Residents of those covered states may have all or various of the privacy rights described above. If you are a resident of a covered state, you may also opt out of “sales,” and “sharing” by broadcasting an opt-out preference signal, called the Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that support such a signal). You can learn more about the GPC here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access the E-Commerce Sites, you will need to renew your opt-out request. (Note that while we honor the GPC, we do not listen for or respond to older, Do Not Track (“DNT”) technologies that users may set in certain web browsers.)
  • Collection, use and disclosure of personal information for business purposes.

• Sensitive Personal Information. We generally do not collect sensitive personal information as defined by certain US state privacy laws from you when you use our Services. However, we may collect sensitive personal information pursuant to this Notice to satisfy our regulatory obligations. We do not use sensitive personal information to profile or infer characteristics about you or other individuals.
• Retention of Personal Information. We store the personal information we collect for as long as necessary to fulfill the purpose(s) for which it was collected and for other purposes described in our full Global Privacy Notice.
• Personal Information We May Share or Sell. We may disclose certain categories of personal information in conducting online advertising and analytics activities. While we do not disclose your personal information for money, these activities may be considered “sales,” or “sharing,” under certain US state privacy laws. We do not have actual knowledge that we “sell” or “share” personal information about consumers under 16 years of age either as those terms are commonly understood or as they are defined under certain US state privacy laws. The table below provides more information about these practices.

• Submitting a Privacy Rights Request. You can manage the way we use your personal information and exercise privacy rights afforded to you under applicable US state privacy laws as described in the Privacy Choices and Privacy Rights sections of the full Global Privacy Notice.
• Notice of Financial Incentive. Our commercial and marketing activities are exclusively designed for and meant only to be offered to adults (“Marketing Programs”). Because these Marketing Programs involve the collection of personal information, they may be considered a “financial incentive” program under certain US state privacy laws. The value of any personal information that may be provided by adults when signing up for any such Marketing Program would be related to the value of any discounts that are received by the participant, less our costs related to administering such Marketing Program(s).

• United Kingdom and European Union. The table below contains a list of the legal bases on which we rely when processing personal data that is subject to applicable data protection laws in Europe, including the EU General Data Protection Regulation (the EU GDPR) and the EU GDPR as it forms part of retained EU law in the United Kingdom, (the UK GDPR). Please also note that if your personal data is subject to the EU GDPR or UK GDPR, you may receive a copy of the safeguards we use to protect your personal data when it is transferred internationally on request.

• Canada. With respect to our operations in Canada, we collect, use, and disclose your personal data with your consent, except as otherwise permitted or required by law. Your consent may be express or implied, depending on the circumstances. Personal data (also referred to as personal information) includes any information about you as an identifiable individual.

We have policies and procedures in place designed to ensure our compliance with this Privacy Notice and applicable laws, including policies and procedures regarding the retention and destruction of personal information, the handling of complaints, and the appropriate management of personal information by our personnel. We restrict access to personal information to those of our personnel with a need to know for the purposes described in this Privacy Notice. If you have any questions, including with respect to our use of service providers outside of Canada, please Contact Us.