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Website Privacy and Data Use Policy
This Website Privacy & Data Use Policy contains information regarding the practices of TGP, a division of Federated Co-operatives Limited, with respect to the collection, use, retention, storage and disclosure of Personal Information. The following defined terms are used within this Policy: “TGP” means TGP, a division of Federated Co-operatives Limited “Personal Information” means information about an identifiable individual. This includes information such as an individual’s name, home address, telephone number, personal e-mail address, and personal Twitter or other social media address. Personal Information also includes demographic information such as an individual’s gender, age, nationality and other characteristics when that information could be combined with other Personal Information. Personal Information may also include information regarding an individual’s product interests, purchasing history and financial information. In some cases, information that appears to be anonymous may be Personal Information if it can be easily linked to an individual to create a profile about that person. An individual’s business address, title, and business telephone number are not Personal Information when used for business purposes. “Policy” means this Website Privacy & Data Use Policy. “Service Providers” means other companies and individuals who provide TGP with services but who are not employees. “Site(s)” means the following website(s): www.tgp.crs and any of its subdomains ending in .tgp.crs “user” means an identifiable individual who provides Personal Information to TGP through the Site(s) or otherwise. TGP may update this Policy without prior notice, and any changes will be effective immediately upon the posting of the revised Policy on the Site(s).
1. Application of this Policy
This Policy applies to Personal Information that TGP collects through the Site(s) and when users contact TGP. Please read this Policy and the Terms of Use carefully. By using TGP’s Site(s), users are agreeing that they understand the terms of this Policy and the Terms of Use.
2. Information TGP Collects
TGP collects information when users provide it to TGP. TGP also collects information about users through automated technologies on TGP’s Site(s) and from third parties. When TGP links information to users that was collected through automated technology, TGP treats that information as Personal Information. A. Information that users provide TGP collects Personal Information from users when users provide it. For example, a user might provide TGP with their Personal Information when they e-mail TGP, telephone TGP, sign up for an e-mail newsletter, submit comments, submit a resume or job application, participate in a promotion, survey or other feature of the Site(s), communicate or interact with TGP through TGP’s Site(s) or a social media site such as Facebook or Twitter. If users do not want their Personal Information collected by TGP, they should not submit it. B. Automated information and cookies When users visit or interact with the Site(s), TGP or Service Providers may use technologies that automatically collect information about how a user accesses, navigates and leaves the TGP Site(s). For example, TGP or its Service Providers will collect information on what other website the user came to before visiting the Site(s), what browser type and operating system the user is using, the Internet protocol (IP) address the user is accessing the Site(s) from, the pages the user is navigating through and what website the user goes to after visiting TGP’s Site(s). In general, TGP does not associate this type of information with other Personal Information about a user except in the case of an investigation into TGP’s website security. TGP’s Site(s) may also use cookies. Cookies are data files that are placed on the device a user utilizes to access TGP’s Site(s). These cookies are used to remember a user’s language preference and to facilitate a user’s navigation of TGP’s Site(s). TGP may also use technologies such as web beacon technologies (sometimes referred to as pixel tags and clear GIFs). These are transparent images that provide TGP or its Service Providers with information about whether a page or e-mail has been viewed or forwarded and may communicate with servers of TGP or its Service Providers in order to obtain images and other content and to relay information about the IP address being used to access TGP’s Site(s) and information about a user’s browser. TGP may use cookies and web beacons to present advertisements to users that TGP thinks may be of interest to a user. Although the information TGP collects through cookies and web beacons is typically not combined with information that would identify a user, there is the potential for this information to be associated with a user and, therefore, TGP treats it as Personal Information. Users should reference Cookies, advertising and how to opt-out [below] for more information on how TGP uses cookies and web beacons and how users may opt-out.
3. Children and Minors
The Site(s) are not directed to or suitable for children under 13. TGP does not knowingly collect Personal Information from anyone under 13 years of age. If TGP becomes aware that TGP has unknowingly collected personally identifiable information from a child under the age of 13, TGP will delete this information from TGP’s records or, if that is not reasonable, TGP will take reasonable available steps to de-identify the information. Children who are over the age of 13 but under the age of majority in the jurisdiction in which they reside should not provide TGP with Personal Information without their parent’s or guardian’s consent.
4. Uses of the Information TGP collects
TGP uses information collected from a user for business purposes. For example, TGP uses Personal Information:
- to respond to a user’s inquiries and provide a user with information, such as information on Retail Membership;
- to register a user for TGP programs;
- to assist in optimizing a user’s experience with TGP by collecting information regarding a user’s product preferences and purchasing history;
- to assist with any consumer safety notifications;
- to monitor product quality and to communicate with users about the quality of TGP’s products;
- to provide users with newsletters and other advertising;
- to provide users with features on TGP’s Site(s), such as community forums or interactive features; and
- to identify participants in contests and promotions.
5. How TGP obtains consent
Users consent to the collection, storage and use of their Personal Information when they provide it to TGP or they provide it to a third party and give the third party permission to send that information to TGP. The purposes for the collection of Personal Information that users provide to TGP are usually stated or implicit in the context in which a user gives it to TGP or a third party acting on TGP’s behalf. If TGP wants to make additional uses of a user’s Personal Information, TGP will ask the user for their express consent. For example, if a user provides TGP with their e-mail address so that TGP can provide the user with a newsletter, TGP obtains the user’s implied consent to use the user’s e-mail address for providing the user with TGP’s newsletters. If a user provides TGP with their e-mail address when they make an inquiry, TGP obtains their implied consent to use it for the purposes of responding to their inquiry. TGP may ask the user for their opt-in consent to use their e-mail for other purposes. TGP uses opt-out consent for cookies and web beacons and other automated information. If a user does not want TGP to collect or use this information, they should not visit TGP’s Site(s). In addition, a user may opt-out by using browser settings that will not accept cookies or setting their e-mail application to not download images. In addition, users may opt-out of certain on-line advertising. Users may reference Cookies, advertising and how to opt-out [below] for more information.
6. How TGP shares Information
TGP may share information that it collects about users in the following circumstances: A. Service Providers providing services to TGP or on TGP’s behalf Service Providers provide services to TGP and may provide services to users on TGP’s behalf. TGP may share a user’s Personal Information or information that TGP has collected through automated means on TGP’s Site(s) with TGP’s Service Providers. For example, TGP’s Service Providers may host TGP’s Site(s), analyze data collected from TGP’s Site(s), provide customer service on TGP’s behalf, provide and manage social media sites on TGP’s behalf, administer TGP’s promotions, provide marketing or promotional assistance, post TGP’s advertisements, and collect user’s feedback on TGP’s Site(s) and advertisements. TGP is a divisionof Federated Co-operatives Limited (“FCL”) and will from time to time transfer your personal information to FCL to allow it to process your personal information for research and marketing purposes. FCL may need to disclose your personal information to third parties with whom it has contract agreements in place for the purposes of managing your personal information such as data collection and processing companies. TGP provides FCL with only that information which is necessary to perform the required services. Other than the transfer of your personal information to FCL for the aforementioned purposes, TGP will not disclose your personal information to any organization without your consent, except where permitted or required by law. B. Aggregated or de-identified information TGP does not sell or rent user’s Personal Information to third parties. However, TGP may share information in aggregated statistics and de-identified form with third parties without a user’s consent. C. When a user specifically agrees to TGP sharing their information In some situations, a user may specifically agree to TGP sharing their information. For example, if a user provides TGP with their contact information, e-mail address, Facebook account, or Twitter account for the purposes of signing up for information or marketing offers from a third party, TGP may share their Personal Information for that purpose. A user’s Personal Information will be subject to the privacy policy and business practices of TGP’s third party. D. Business Mergers or Acquisitions TGP may sell or purchase assets. If another entity acquires TGP, or all or a portion of TGP’s assets, information that TGP collected from users may be shared with that entity. The information will be shared for the purpose of that entity considering whether to enter into the transaction and also to complete the transaction. Should such a sale or transfer occur, TGP will use reasonable efforts to direct that entity to use the user’s information in a manner that is consistent with this Policy and the purposes for which the information was originally collected. Also, if any bankruptcy or reorganization proceeding is brought by or against TGP, a user’s information may be considered an asset of TGP’s and as such may be sold or transferred to third parties in those proceedings. E. Other legally required or permitted disclosures TGP may also disclose the Personal Information of users in the following circumstances: (a) if such disclosure is necessary for TGP to receive legal advice; (b) to collect a debt from a user; (c) if TGP is required to disclose a user’s Personal Information in order to comply with any legal obligation or the decision of a judicial authority; (d) if disclosure is requested by an investigatory body, law enforcement official or governmental authority which has lawful authority to request the disclosure of the information in respect of an investigation; (e) if TGP has reasonable grounds to believe that the information relates to a breach of an agreement or contravention of a law; or (f) where TGP is otherwise permitted to do so by applicable law.
7. How TGP protects Personal Information
TGP retains the Personal Information of users to fulfill the purposes for which it was collected. TGP maintains and also requires its Service Providers to maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of Personal Information. For example, TGP uses password protection where appropriate and limits access to staff, employees, and Service Providers who need to have access to it for the purposes for which it was collected and who have acknowledged their obligations to protect the Personal Information. When TGP transfers Personal Information, TGP uses encryption where appropriate. TGP cannot, however, guarantee the security of Personal Information held or transferred by it. If a user is located in Canada, they should be aware that information TGP collects may be transferred to and processed in the United States and other countries in which TGP Service Providers have operations. Although TGP requires Personal Information being handled by its Service Providers to be protected to comparable levels of security as would be required in Canada, the privacy laws in these other jurisdictions may not be as comprehensive as or equivalent to those in Canada.
8. Links to External Content
TGP’s Site(s) may link or direct a user to other websites, services or external content resources which are outside of TGP’s control. Once a user has left TGP’s Site(s), TGP cannot safeguard and is not responsible for the protection and privacy of any Personal Information which a user provides on other websites. These other websites may send their own cookies to a user’s device and may independently collect data or solicit Personal Information. Please review the applicable terms of use and privacy policies for those other websites.
10. Accessing Personal Information
If a user wishes to verify, correct, or update any of their Personal Information collected by TGP or its Service Providers acting on TGP’s behalf and that TGP has received from these Service Providers, the user may do so by contacting TGP by visiting the Contact TGP page. TGP may request Personal Information from the user in order to authenticate the user’s identity before providing the user with access to their Personal Information or complying with any request to correct or update their Personal Information. Please also note that in some cases TGP may legally deny the user access to the information that TGP has collected about the user. For example, this may occur where the information is subject to solicitor-client privilege or consists of references to other persons or proprietary information that cannot be severed. TGP may routinely delete certain records that contain Personal Information in accordance with its’ record-keeping practices. Although TGP will make efforts to comply with any request that a user may make to destroy Personal Information about the user that is not otherwise required by TGP to fulfill legal requirements or to protect TGP’s interests, the user should be aware that it is not always possible to completely remove or delete all of the user’s Personal Information from TGP’s databases without some residual copies of data because of backups, archival systems and other reasons. TGP will not, however, continue to use a user’s Personal Information for active purposes once the user has requested TGP not to do so.
11. Online eStore and Online Ordering
A. Availability The purchase of products on the eStore Website is subject to availability at the time of ordering. B. Price Prices are subject to change without notice. Certain items are estimated costing and may not reflect the invoiced price. C. Terms All purchases are subject to the agreed upon Terms as defined upon the opening of your TGP account. Therefore, each time you place an order with TGP through the eStore Website you represent that you have accessed, read and accepted the Terms applicable to and governing that order. D. Limitations of Liability TGP is not liable for any direct, indirect and/or incidental damages of any nature (including loss of use, loss of data, loss of profit and loss of savings) to you or your device including damages arising in connection with or relating in any manner whatsoever to: (A) this eStore Website; and (B) any content, and (C) any transaction conducted; and (D) any unauthorized access to or alteration of your data on the eStore Website. E. General All Terms and Conditions previously agreed upon govern your use of the eStore Website. The agreement between you and TGP with respect to any purchase made by you on the eStore Website TGP shall not be liable for any delay or failure to perform any of its obligations under these Terms if such delay or failure is due to causes beyond its control including, without limitation, weather-related and other uncontrollable shipping delays. F. TGP Website Privacy and Data Use Policy By using the eStore Website, you also agree to the rest of the TGP Website Privacy and Data Use Policy as outline in the rest of this document.
12. How to contact TGP
If a user has any questions or comments about this Policy, TGP may be contacted by visiting the Contact TGP page.
13. When this policy was updated
This policy was last updated on November 1, 2016.