Privacy Policy

Last updated on August 26, 2023.

13895807 CANADA INC. (O/A MyCircles, hereinafter referred to as “we” or “our”) respects your concerns about privacy. This Privacy Policy Statement (“Policy”) explains what personal information we collect through our websites and online services, how we use that information, to whom we disclose it, and how we safeguard personal information.  Unless indicated otherwise, this Policy applies only to personal information collected through the websites, microsites, mobile applications, and/or other online services of MyCircles that expressly adopt, display or link to this Policy, and then only to the extent indicated (collectively, the “Services”).

 

WHAT INFORMATION DO WE COLLECT AND WHAT DO WE DO WITH IT?

1. Information You Provide

When you visit our Services, you may provide us with certain personal information, such as your name, address, phone number, email address, social media, personal preferences, payment card number, purchase and/or ordering information, demographic information, responses to survey questions, sizing information and any other information you choose to provide.  Our Services may also give you the option to upload or share pictures or videos of yourself and others.

We may also collect information that you provide on our Services about people you know.  For example, we collect your gift recipient’s contact information to process your gift orders.  We may also collect contact information about your friends and family members when you participate in one of our referral programs. 

2. Information Your Devices Provide Automatically

When you interact with our Services, we also obtain information by automated means, including the following:

  1. Location Information

We may obtain information about your location when you access or use our Services:  for example, via your browser information and other similar device or browser attributes (like IP address), our store locator page, or our mobile applications.   

  1. Navigational Information

When you access our Services, your computer, phone, or other device may provide navigational information, such as browser type and version, service-provider identification, IP address, the site or online service from which you came, and the site or online service to which you navigate.

  1. Device Information

We also may obtain information about the computer or mobile device you use to access our Services, such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website or app usage behavior.

  1. Cookies, Clear Gifs and Similar Technologies

To better understand how you interact with our Services, we may collect information using cookies, clear-gifs (also known as web beacons or web bugs) and similar technologies.

A cookie is a small amount of data that’s stored by your browser on your device. It’s used to do things like see how you navigate our Services, what you click on, remember you and your online purchases when you return, and recognize you and honor a special deal for you, when you redeem one of our offers from a third party’s site. This helps us improve and deliver our Services, provide better customer service, tailor and improve your online experience, and tailor offers to you based on your unique tastes and a combination of your online interactions and purchase history.

A clear gif is a nearly invisible pixel-sized graphic image on a web page, web-based document or email message. It helps us do things like view the URL of the page on which the clear gif appears and the time the site, document or email in question is viewed; and recognize you and honor a special deal for you, when you navigate from a third party’s site to redeem one of our offers that may have appeared there. Clear gifs in emails help us confirm the receipt of, and response to, our emails, including those that you forward to friends and family; and they help deliver a more personalized or better online experience.

In addition to cookies and clear gifs, we may also use device identifiers, web storage, and other technologies to collect information about your interactions with our content and Services.

These technologies, illustrated above, may be used to help us see which of our interactive experiences online users like most. Cookies, clear gifs, and similar technologies also allow us to associate your online navigational information and purchases and interactions (both online and offline) with personal information you provide (such as name, address, phone number, survey responses, and email address). We associate this information to deliver products and services to you; improve our business; transact business; and market our products and services on this and other online services, and through a variety of media like email, mobile advertising, and direct mail.

3. Information Derived Through or Provided By Others

Affiliated entities, vendors, merchants, social media networks, and advertising networks may provide us with, or supplement, information about you.  We may use this information for a variety of operational or marketing purposes, such as to correct shipping information, market to you, deliver more relevant offers through customer insights, improve our business, and transact business.

4. How We Use the Information We Obtain

We use the personal information we obtain through our Services to:

  1. deliver our Services
  2. process your online orders;
  3. facilitate payment and transactions;
  4. create and manage your online account;
  5. personalize your online experience with content and offers that are tailored to your interests;
  6. provide customer service and respond to your inquiries and requests;
  7. include you in surveys and contests;
  8. enable you to post your content, such as comments, images or videos;
  9. facilitate networks of online social activity centered around our products and services;
  10. improve our Services, the manner in which offers are made on our Services, and the interactions and experience visitors have with our Services;
  11. enable you to interact with third-party content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment;
  12. market our products and services that may be of interest to you; and
  13. create aggregated, pseudonymized or anonymized information for statistical purposes. 

 

5. Third Party Analytics and Personalization Services

We may use third-party analytics and personalization services to analyze site metrics and performance, analyze our visitors’ preferences, and serve personalized content to you through the use of some or all of the technologies described above, such as cookies and clear gifs.

 

CONSENT
1. How Do You Get My Consent?

When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.  If we ask for your personal information for a secondary reason, such as for advertisements, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

 

2. How Do I Withdraw My Consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by sending your request to privacy@mycircles.ca .

 

3. Age of Consent

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

 

CHILDREN’S PRIVACY  

We do not knowingly solicit, collect, maintain or use personal information from children under 13 years of age, and no part of our Services is directed to children under the age of 13. If you believe that your child has provided us with personal information please contact us by email at privacy@mycircles.ca.  If we become aware that we have collected personal information from a child under 13, we will promptly delete such information from our records and terminate the child’s account, if any.

 

MARKETING

On our Services, we and third parties may collect information about your online activities to provide you with advertising about products and services tailored to your interests.  We contract with third-party advertising companies, which may collect information about your use and interactions with the Services, over time and across third-party websites and online services, for use in delivering tailored online display and banner advertising to you on other websites and online services. To serve this advertising, these third-party companies place, use, or rely on the technologies described above, including cookies, clear gifs, device identifiers and similar technologies to obtain information about customer interactions with us through our Services and interactions with other online services. These companies use the information they collect to serve you ads that are targeted to your interests.

You may also specify your preferences through a centralized registry.  To learn about how to opt out of interest-based advertising, in general, click the following: NAI Opt Out or, DAA Opt Out. Your mobile device settings may allow you to prohibit mobile app platforms (such as Apple and Google) from sharing certain information obtained by automated means with app developers like us and other businesses.

 

INTERACTION WITH THIRD PARTY SERVICES

We link to third-party sites and services, or otherwise display third-party content through our Services, for your convenience and information. These third-party sites and services may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked third-party sites and services are not owned or controlled by us, we are not responsible for these third parties’ information practices.

Here are examples of the types of third-party content and services available through or via our Services:

1. Social Networking and other Third-Party Sites and Services

We may at times facilitate easy access to third-party sites and online services, like social networks and other services that host user-generated content. This may include easy click-through access, the ability for you to share content on third-party services, or even “single sign-on” to these services. The third-party’s privacy policy applies to any information or content you provide through these services.

 

DISCLOSURE

We may share information about you with certain third parties, as described below, and as otherwise described in this Policy.  We do not sell or otherwise share personal information about you, except as described in this Policy. 

1. Law Enforcement and Emergency Response

We may disclose personal information about you (a) if we are required to do so by law or legal process (such as court order or subpoena); (b) in response to requests by government agencies, such as law enforcement authorities; (c) to establish, exercise, or defend our legal rights; (d) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (e) in connection with an investigation of suspected or actual illegal activity; or (f) otherwise with your consent. 

2. Service Providers and Contractors

We may share personal information with third-party service providers and contractors whom we engage to provide services to us, such as fulfilling orders; processing payments; providing customer service through chat features; monitoring activity on our Services; delivering surveys and related analysis (which could be combined with Services usage analytics); maintaining databases; hosting and operating our microsites, mobile websites and mobile applications; administering, sending and monitoring emails and text messages; serving online advertisements as described above; and providing consulting services.

Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.  For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. 

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

3. Other Marketers

We may share your personal information (such as your name, postal address, and summary purchase information) with merchants on our platform and they may use this information to send you offers for their products and services. We will obtain your consent for this sharing to the extent required by applicable law. If you don’t want this information shared with these merchants and exchanges, please email us at privacy@mycircles.ca with Nondisclosure of Personal Information Request for the Email Subject.

We may occasionally provide you with the opportunity to opt in to receive email messages from third parties. If you do opt in, we’ll share your email address with the specific third party in question. Please review the privacy policies of these third parties to learn more about how they will treat your personal information.

4. Sale or Merger

We reserve the right to transfer your information in the event we sell or transfer all or a portion of our business assets (including, without limitation, in the event of a merger, acquisition, joint venture, reorganization, dissolution, or liquidation).

 

LIMITING THE USE OF YOUR INFORMATION

We offer you certain choices in connection with the personal information we obtain about you.

1. Email

You may opt out of the MyCircles email list by following the instructions located at the bottom of each commercial email or by emailing us a request to opt out via privacy@mycircles.ca. If you opt out of our email lists, we may still send you operational or transactional messages, such as password-reset or account related information, from the relevant brand.

2. Mobile Text Messaging

If you’ve signed up for mobile text messaging offers but later decide you no longer wish to receive these offers, simply follow the opt-out instructions included in the mobile message.

3. Mobile Push Notifications/Alerts

With your consent, we may send push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

4. Location Information

You may have the ability to turn location-based services on and off by adjusting the settings of your Internet browser or mobile device or, for some devices, by adjusting the permission settings for our mobile apps to access your location information.

5. Cookies and Clear Gifs

Visit our Marketing Section of this Policy to learn about how to specify your preferences over our use of cookie and similar technologies.

6. Other Marketers

If you don’t want your information shared with other merchants and exchanges for those third parties’ own direct marketing purposes, please email us at privacy@mycircles.ca and use Nondisclosure of Personal Information Request for the Email Subject. 

 

SECURITY

To protect your personal information, we maintain administrative, technical and physical safeguards designed to protect the personal information we collect through our Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. 

Our administrative safeguards include implementing, maintaining and training employees on company privacy and information security policies and procedures.  Our physical and technical safeguards include maintaining physical security policies and standards to protect company systems and data, and a cybersecurity program overseen by our executive leadership team.  

For instance, if you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with an AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

Our employees involved in data processing and our servers are based in Toronto, Ontario, Canada, and other locations throughout Canada.  We also work with affiliated and unaffiliated service providers in Canada, United States, and other jurisdictions around the world. 

 

CHANGES TO THIS PRIVACY POLICY

This Policy may be updated periodically to reflect changes in our personal information practices.  Changes and updates will take effect immediately upon their posting on this page. If we make material changes to this Policy, we will notify you by posting a prominent notice on our Services indicating at the top of the Policy when it was most recently updated. 

 

QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information about our Policy, you can contact us at privacy@mycircles.ca.