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Privacy Policy

At Comark Inc., we value our customers and respect their privacy rights and concerns. This is the Privacy Policy for Comark Inc. and the Comark Divisions – Bootlegger, Ricki’s and cleo (collectively, “Comark", “we”, “us”, “our”), in which we explain our practices and policies for the collection, use, and disclosure of your personal information (this “Privacy Policy”).

By using our a Comark website or mobile application (each a “Site” and, collectively, the “Sites”) or otherwise providing us your personal information, you consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy. If you have any questions about this Privacy Policy, please contact our Privacy Officer at the address provided below.

We reserve the right to change the terms of this Privacy Policy at any time. When we make changes, we will revise the date at the top of this Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you by prominently posting a notice of such changes on our Sites, or by sending you an email, in each case in accordance with applicable law. We encourage you to review this Privacy Policy whenever you visit our Sites.


The Information We Collect

For the purposes of this Privacy Policy, “personal information” means any information that can identify you, either on its own or in combination with other information.

Comark collects personal information from you by various methods including information actively provided by you through our physical stores and/or Sites and as otherwise contemplated in this Privacy Policy. The types of personal information we may collect include your name, address, phone number, email contact information, and purchasing information (such as order history).

How We Use The Information

We use your personal information for the following purposes:
a) Creating an account for our Sites;
b) Processing and completing purchases, returns and similar transactions;
c) Providing customer service;
d) Notifying you of product recalls or providing other information concerning products you have purchased;
e) Subject to our obligations under applicable anti-spam laws, sending you marketing information about Comark products;
f) Sending you information about purchases you have made;
g) Identifying your product and service preferences, providing personalized content and informing you of new or additional products, services and promotions that may be of interest to you;
h) Identifying and preventing fraud;
i) Protecting our own rights and interests, such as to resolving any disputes, enforcing our contractual arrangements with you and responding to legal inquiries; and
j) For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Comark may also collect personal information from you when you apply for employment with Comark. Such information will include your name, address, phone number, email contact information, employment history and any other information included in your application (including any information contained in your cover letter and/or resume). We will use this information for the purpose of contacting you, assessing your suitability for employment and as otherwise required under applicable law.


Who We Share The Information With

Except as set out in this Privacy Policy, Comark does not disclose your personal information to any third parties. We may, however, share your personal information in the following circumstances:

Affiliates and Business Transfer. We may share your personal information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.

Service Providers. We may share your personal information with third-party service providers who perform services on our behalf. For example, we may hire other companies to handle payments processing, provide data storage, fulfill orders and shipments, assist in marketing, conduct audits, and so forth.

Other. We reserve the right to share your personal information if required or permitted to do so by law.

Data Transfers

Some of the parties to whom we may provide your personal information may be located in jurisdictions outside your jurisdiction of residence. For example, we are headquartered in Canada and some of our data centers are located in the United States. As a result, your personal information will be used, stored and/or accessed in Canada and the United States and possibly other jurisdictions. Please note that when your personal information is located outside of your jurisdiction of residence, it will be subject to the laws of the country in which it is situated and these jurisdictions may not have an equivalent level of data protection laws as those in jurisdiction of residence.


Security

We take the protection of your personal information seriously. We employ a range of safeguards designed to protect personal information against loss and theft as well as unauthorized access, disclosure, copying, use, and modification, including physical, organization and technological measures, commensurate with the sensitivity of your personal information. Our employees have access to your personal information only on a strict need-to-know basis, are trained in the proper handling of such information, and are required to keep such personal information confidential and use it only for the purposes for which it was provided.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any other purpose.

Secure Sockets Layer ("SSL") technology is used to protect the security of your credit card information as it is transmitted. SSL is the industry standard for secure commerce transactions. It is designed to prevent your personal information from being read by someone else as it travels across the Internet. All of your personal information is encrypted, including credit card number, name and address. Please be aware that no data security measures can guarantee 100% security. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.


Accessing and Updating Information

You have the right to know what personal information about you we possess and to update or correct your personal information. To access, update or correct your personal information, please contact our Privacy Officer at the address provided below.

Retention of Information

We will only retain your personal information as long as is necessary for the fulfillment of the purposes for which it was collected or as required by law. Your personal information is securely stored until such time as it is no longer required, after which it is destroyed, rendering it unable to identify you.


Information You Disclose Publicly

Subject to applicable laws and any applicable third party terms (for example terms and conditions of applicable public forums): (a) we may publish your name, voice, likeness and other personal information that is part of your ideas, photographs, videos, audio recordings, questions, comments, suggestions or other content (collectively, "User Content"), on blogs and message boards, product reviews and other public forums, and we may use the content, or any portion of the content, for marketing, publicity and promotional activities; and (b) by connecting with us through our social media pages or accounts, or by posting content using our created hashtags or other identifiers, you are providing your consent for us to use any personal information or other content you submit or make available through such sites for marketing and promotional purposes, including, but not limited to, incorporation into our marketing materials, without further notice or compensation.


Cookies and Tracking Technologies

As you use our Sites, we may collect other information, such as information about how you use and interact with our Sites using cookies and other similar technologies.

How does Comark use cookies and other similar technologies?

Cookies: Cookies are small text files that are placed on your computer’s hard drive, through your web browser, for record-keeping purposes. We might use cookies to uniquely identify your browser/device/IP address, in order to help us to process your transactions and requests, to track aggregate and statistical information about user activity, and to display advertising both on our Sites and on third-party sites. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies some features of our Sites may not function. Further information may be found at www.allaboutcookies.org.

Clear GIFs. Clear GIFs (a.k.a. web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. These “images” are automatically loaded to your browser/device when you visit our Sites or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. Clear GIFs allow us to record simple user actions related to our websites and to email communications received from us, to help us determine the usage and effectiveness of our site and communications. We might use clear GIFs to track the activities of our visitors and app users, help us manage content, and compile statistics about usage. We and our third party service providers also might use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. These can be blocked either by using a third party application such as Ghostery (https://www.ghostery.com), or, in the case of emails, by changing your settings to prevent images from being downloaded (where your email client supports this functionality).

Third-Party Analytics: We work with third-parties data analysis companies that use their own tracking technologies (including cookies and pixel tags) on our Sites and on the websites and apps of third parties across the Internet in order to develop statistical profile information about our users generally, which assists us in better understanding our customers and potential customers, and tailoring our products, services and marketing activity in order to best address the needs and interests of our target market. The information collected does not include your name, postal or email address, or any commonly-used identifiers; rather, the data collected is tied only to a set or browsers or devices, which is not linked to the name of a device or browser user, their street address, etc. These analytics companies may collect information about your activity across your different devices on our Sites and third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about the preferences of our customer base, or segments thereof.

You may opt-out of such profiling here


Links

The Sites may contain links to information at other third party websites. When you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites as their privacy policy may differ from ours.


Contact Us

If you would like to know more about our privacy practices, including our use of service providers outside your jurisdiction of residence, or if you would like to exercise certain rights under this policy (including the right to have your personal information deleted), please contact our Privacy Officer at the address below:

The Privacy Officer—Comark
2345 Argentia Road, Suite 102A
Mississauga, ON.
L5N 8K4

For information collected by our divisions, please make your request in writing to:

Attention: Privacy Representative
C/O the Human Resources Department

Cleo
2345 Argentia Road, Suite 102A
Mississauga, ON.
L5N 8K4

Ricki's
1530 Gamble Place
Winnipeg, MB
R3T 1N6

Bootlegger
4460 Jacombs Rd.
Richmond, BC
V6V 2C5