The purpose of this Privacy Statement is to inform you about the types of personal information Jdd-protwell Canada Ltd. (as follows, “Protwell”, “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.

Collection of Personal Information

a. 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 any information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work electronic address.

b. 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, participate in a promotional offer, including one that requires you to submit a receipt, or contact Consumer Affairs. 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
We may also collect your demographic data, such as your gender and postal code, and information found on a retail receipt such as your basket size/total purchase amount and products purchased, 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, to determine aggregate consumer preferences and purchasing patterns, and promotion evaluation, development and implementation. 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.

c. How do we use technology to collect information through the Sites?
We collect anonymous information about any user of the Sites. This anonymous information may include a user’s browser type, type of computer operating system, and the domain name of the website from which the user linked to the Sites. This information is collected for Protwell’s internal use, such as to enhance website security, to detect broad demographic trends, to assist Protwell in providing content tailored to a user’s interests and to otherwise enhance the user experience on the Sites.
We may use a “cookie” or similar technology to assist us to customize the Sites. A “cookie” is a data file that a website sends to a user’s computer while that user is viewing the site. These data files include information that allows a website to remember information that will make that user’s use of the website more efficient and helpful to him or her. Cookies do not damage computer systems or files, and only the website that transferred a particular cookie to you can read, modify or delete such cookie.
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 that declining cookies may significantly impair your use of our Sites.

d. What information do we collect?
· Personal information you disclose to us
We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
· Publicly Available Personal Information.
We collect first name, maiden name, last name, and nickname; email addresses; phone numbers; business email; business phone number; current and former address; and other similar data.
· Personal Information Provided by You.
We collect purchase history; financial information (credit card number, purchase history, invoices); and other similar data.
· Payment Data.
We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe and PayPal. You may find their privacy policy link(s) here: https://stripe.com/privacy and https://www.paypal.com/va/webapps/mpp/ua/privacy-full. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Use of Personal Information

a. How do we use your information?
We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
· To facilitate account creation and logon process.
If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
· To send you marketing and promotional communications.
We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
· Fulfill and manage your orders.
We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
· To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

b. When and how do we obtain your consent?
We obtain your consent prior to collecting, using or disclosing your personal information for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances. In limited circumstances, we may rely on a third party to obtain your consent to the sharing of your personal information with us.
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, use or disclose your personal information based on your consent and as permitted by law.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
· Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
· Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
· Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
· Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
· Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
· More specifically, we may need to process your data or share your personal information in the following situations:
· Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.
· Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

WHO WILL YOUR INFORMATION BE SHARED WITH?

We only share information with the following third parties.
We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
· Invoice and Billing
PayPal and Stripe
· Web and Mobile Analytics
Google Analytics

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at contact@jdd-ceremica.com.

WHAT ARE YOUR PRIVACY RIGHTS?

You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at contact@jdd-ceremica.com

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:
· Log into your account settings and update your user account.
· Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may: Contact us using the contact information provided.

DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Protwell believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Protwell becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Protwell will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

DO WE MAKE UPDATES TO THIS POLICY?

Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer by email at contract@jdd-ceremica.com

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: https://protwell.com/my-account/ or email contact@jdd-ceremica.com. We will respond to your request within 30 days.