In this Policy, the terms “ITCAN”, “we”, “us” and “our” are used to refer to Imperial Tobacco Canada Limited.
Protecting your privacy is important to ITCAN. The purpose of this Policy is to explain how we collect, use, disclose and otherwise manage personal information.
This Policy applies to and governs the activities of ITCAN and is meant to exclude the personal information concerning individuals who seek to be, are or were employees of ITCAN as a specific policy is applicable to those individuals.
Personal information is any information about an identifiable individual, whatever the nature of its medium and whatever the form in which it is accessible, whether written, graphic, taped, filmed, computerized or other. Information concerning a company or a partnership is not personal information. This Policy applies to personal information that is in ITCAN’s possession or that is under its control, including information that it may transfer to a third party for warehousing, storage or processing purposes.
If we have obtained your consent to collect, use or disclose your personal information, you can withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please note that if you choose to withdraw your consent, ITCAN may not be able to provide the services you request.
In general, ITCAN collects personal information about you that is necessary for the purposes of establishing, managing and maintaining our relationship with you, or that is necessary to provide the services you request. For example, personal information may be collected when you:
In most circumstances, we will obtain your personal information directly from you. However, we may also collect personal information about you from outside sources, such as when the collection from a third person is necessary to ensure the accuracy of the information you have provided, if the source is legally allowed to disclose personal information about you.
When you join pallmall.ca, we collect your first and last name, your home address(es), your email address, date of birth. We use this to confirm your eligibility for pallmall.ca and, if approved, to administer your account, provide you with access to the pallmall.ca platform (including customized content and product news), and to send you pallmall.ca communications that may be of interest to you.
In conformity with the applicable tobacco legislation, we collect your date of birth to verify that you are an adult of legal age to consume tobacco products. We also use a third party to verify your age by confirming that the date of birth you provide to us matches the date of birth on your credit file (but we do not obtain any credit-related information from you).
We may also collect your mobile phone number if you wish to receive pallmall.ca communications by SMS text message.
Imperial Tobacco Canada Limited and its affiliate, Imperial Tobacco Company Limited, use a centralized system to administer their sites. You can log in to this pallmall.ca website by using your existing credentials with our brands or with Imperial Tobacco Company Limited’s platforms. If you choose to use your existing pallmall.ca credentials on a site that is operated by Imperial Tobacco Company Limited, we will disclose your personal information in a confidential manner to Imperial Tobacco Company Limited for the purposes of enabling you to access their website in a seamless manner.
If you contact us to request publications or information, we may collect your name, mailing address or email address in order to respond to your request.
We may offer you the ability to sign-up to receive ITCAN marketing communications (such as du MAURIER). If you sign-up, we collect certain personal information (such as first and last name, email address, mailing address) which we use to send you email and other communications that may be of interest to you. You can opt-out of receiving promotional email from us by following the opt-out or “unsubscribe” instructions provided in your email or by contacting us as set out below.
Individuals registered on pallmall.ca can, at any time, unsubscribe from receiving electronic notifications, or manage their notifications, by clicking the unsubscribe mechanism contained in each notification or by logging into pallmall.ca and editing their notification settings.
Please note that you may continue to receive certain transactional and account-related electronic messages from us.
If you contact us with a questions, comment, complaint or suggestion, you may be asked for information that identifies you (such as your name, date of birth, address, email address and a phone number (optional)) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service and product and service offerings.
From time to time, we may offer you the opportunity to participate in one of our surveys or other research activities. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form. We use this information to help us understand our customers and to enhance our product and service offerings.
ITCAN may also use personal information to better understand our customers, to help us improve our products and services, to prevent errors and fraud, and as otherwise required or permitted by applicable law.
Our website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our website. These tracer tags are used to help us optimize and tailor our website for you and other future visitors to our website.
ITCAN has put in place a series of security safeguards designed to protect your personal information against loss and theft, as well as unauthorized access, disclosure, copying, use and modification, regardless of the format in which the information is held.
These security safeguards include physical measures, administrative measures and technological measures that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored.
ITCAN also takes the necessary measures to ensure that all its managers and employees are informed on the contents of this Policy and requirements under applicable privacy legislation, and understand that they are required to conform to it at all times. Access to personal information strictly limited on a need-to-know basis to the persons for whom such information is necessary for the performance of their functions and duties. Unauthorized access to or disclosure of your personal information by an ITCAN employee is strictly prohibited and will result in appropriate disciplinary measures.
ITCAN will keep your personal information for the time required to fulfill the identified purposes, its legitimate business purposes and to conform to legislative requirements.
ITCAN recognizes that it is important to keep personal information accurate, complete and up-to-date and takes reasonable steps to ensure the accuracy and completeness of the personal information it uses and discloses. However, you are responsible to inform ITCAN at the contact information set out below of any significant change in your personal information which may occur during the course of our relationship.
You have the right to request access to your personal information which is in the custody or control of ITCAN, subject to limited exceptions prescribed by law. You can also request that information which is inaccurate or incomplete be rectified.
ITCAN will respond to every request for access and rectification, in accordance with applicable laws. In the event that ITCAN cannot provide access to or rectify your personal information, it will inform you of the reasons why, subject to any legal or regulatory restrictions, and it will provide you with any recourse available. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
All questions or concerns regarding this Policy or about the collection, use and disclosure of your personal information, including requests for access or rectification, should be made in writing to ITCAN’s Privacy Officer at:
Imperial Tobacco Canada Limited
3711, St-Antoine West
Montréal (Québec) H4C 3P6