Effective Date: April 7, 2021
Tree Line Pet Wellness Corporation (“Waggle Mail”, “Waggle Mail Pet Wellness”, the “Company”, “we” or “us”) respects the privacy of our customers and others who use the Services (collectively or individually, “you” or “customer”) and wants you to know and understand how we collect, use, and disclose Personal Information from and about you. By visiting any of the Sites, setting up a customer account (an “Account”), and/or using the Services, you have read and accept the practices set out in this Policy.
WHAT IS PERSONAL INFORMATION?
For the purposes of this Policy, the term “Personal Information” means any information that is defined to be personal information under applicable privacy laws. Usually, this refers to any information about an identifiable individual or any information that can be used to identify an individual and may include, for example, photo identification, name, home address, date of birth and gender, your credit card information, or any personal identification numbers. In most circumstances, Personal Information does not include business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information is not Personal Information under this Policy.
PERSONAL INFORMATION WE COLLECT
We do not automatically collect information about you. We only obtain Personal Information about you as set out below to provide the Services. If you refuse to provide us with certain Personal Information necessary to use the Services or ask us to delete certain Personal Information, we may not be able to deliver the Services.
- Information collected directly from you.
You may provide Personal Information such as your name, username, email address, postal mailing address, and payment information when you create an Account. For example, the categories of information that we may collect directly from you may include the following:
- Identifiers, such as your name, postal address, email address, account name, and other similar identifiers;
- Demographics, such as your gender, age;
- Commercial information, such as products or services purchased, other transactions, or consumption histories or tendencies; and
- Payment information (e.g., credit card or debit card numbers and expiration dates).
- Information automatically collected about you.We and our service providers and business partners may collect Personal Information about you automatically using cookies and similar technologies, including information about your online activities over time and across different websites or online services. You may be able to limit our ability to automatically collect certain types of information by adjusting the cookies settings on your web browsers. We also may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include Personal Information. For example, it allows an email sender to determine whether a user has opened a particular email. The categories of information we may collect via such technologies include:
- Identifiers, such as unique device identifiers, cookie numbers, IP addresses, and other persistent identifiers;
- Geolocation data, such as precise location collected from your mobile device or location information inferred from your IP address or other network information;
- Commercial information, such as products or subscriptions purchased, content downloaded from our sites, or other transaction histories or tendencies; and
- Internet or other electronic network activity information, such as information regarding your interactions with the Waggle Mail Services, the URLs you visit before and after the Waggle Mail Services, and information about the software and hardware you use.
- Information collected from other sources.
We may collect Personal Information from other sources. For example:
- Identifiers. We collect contact information such as email addresses from marketing services, data suppliers, and social media services;
- Commercial information. We collect information on your purchasing history and potential interests from data supplementation services;
- Demographics, such as your gender, age, provided by marketing companies, data supplementation services, social media services, and digital advertising companies; and
- Internet or other electronic network activity information. We collect information from third parties that provide analytics or digital marketing services.
We may combine Personal Information collected through the Sites and Services with other information that we or third parties collect about you in other contexts, such as our communications with you via email or phone, or your customer service records. We will treat such combined information as Personal Information and protect it in accordance with this Policy.
HOW WE USE THE INFORMATION THAT WE COLLECT
Waggle Mail uses the Personal Information that we collect for a variety of purposes, including:
- To confirm your identity when you register as a customer for an Account and manage your Account and profile;
- to respond to your questions or requests concerning the Services, or other services provide by Waggle Mail and/or our partners;
- to fulfill the terms of any agreement you have with us;
- to fulfill your requests for our services and orders for products or otherwise complete a transaction with you;
- to manage your participation in surveys, contests, or promotions;
- to send you information about our Services, the status of any orders, and other topics that are likely to be of interest to you, including newsletters, updates, or other communications;
- to authenticate billing and identification information;
- to deliver confirmations, Account information, notifications, awards, service-related announcements, and similar operational communications;
- to improve or personalize your user experience;
- to improve the quality of our products and services;
- to protect our rights and interests;
- to analyze how visitors use and interact with the Services;
- to learn about users’ demographics, interests, and behavior;
- to provide you with advertising that we believe suits your interests;
- to comply with legal and/or regulatory requirements;
- to manage our business; and
- to ask for your consent to process your Personal Information for a specific purpose that we communicate to you. When you consent to the processing of your Personal Information for a specific purpose, you may withdraw your consent at any time and we will stop the processing of your data for that purpose.
We may partner with certain third parties to collect, analyze, and use information collected via the Services or in email communications from Waggle Mail. This information may be used for a variety of purposes, including online behavioral advertising, as discussed below (see the section entitled “How we share Personal Information with third parties”).
We also may use information that we collect to send you promotional communications, including emails or postal mail about the products and services offered by Waggle Mail or our partners. Although we hope you will find our promotional emails of interest, you may opt out of receiving them by clicking on the “unsubscribe” link in any promotional email.
HOW WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES
Privacy legislation requires that we obtain the consent of an individual for the collection, use or disclosure of Personal Information in many circumstances. By providing your Personal Information to us, you agree that we may collect, use and disclose your Personal Information in accordance with this Policy and as otherwise permitted or required by law, and that we may access, process and store your Personal Information in Canada or another jurisdiction.
When we receive Personal Information from you for the purposes of providing you with the Services or for other uses identified in this Policy, you are providing us with consent to deal with your Personal Information for the following purposes.
- Service providers and business partners: We engage service providers and business partners to assist us with operating and providing you our services. These service providers or business partners may perform marketing services, help us process or ship orders, support email and messaging services, support our online advertising efforts, help us learn about customer trends and interests, and analyze information. Some of our service providers or business partners may engage their own service providers or business partners to further assist us. Unless otherwise specified, these companies will only use your Personal Information in the ways described in this Policy.
- The Services also enable third-party tracking mechanisms to collect information for use in online behavioral advertising. For example, third parties may use the fact that you visited the Sites to target online ads for Waggle Mail services to you on non-Waggle Mail websites or services. In addition, our third-party advertising networks might use information about your use of the Services to help target non-Waggle Mail advertisements based on your online behavior in general. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
- The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here. Our Services currently do not respond to “do not track” browser headers.
- To comply with law or cooperate with reasonable requests: We may share your Personal Information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation. We may share Personal Information as we deem reasonably necessary to support lawful investigations or otherwise to protect our rights or the rights of you or any other party.
- In the context of a transaction: We may share your Personal Information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business.
We do not sell your Personal Information in exchange for money. However, we may disclose information to third parties in exchange for analytics, insights, marketing support, or other valuable services. California law treats such disclosures as “sales” even though the information is not exchanged for money. We disclose the following categories of information for such purposes:
- Commercial information;
- Geolocation data;
- Internet or other electronic network activity information; and
- Inferences regarding preferences or other characteristics.
Your direct sharing of information on the Services. Certain features of our Services make it possible for you to share comments or feedback publicly with all other users of the Services. Any information that you submit through such features will be available to the public at large and potentially accessible through third-party search engines. Such information can be read, collected, and/or used by others, and it could be used to send you unsolicited messages if you disclose Personal Information. Accordingly, please take care when using these features of the Services.
Your direct sharing of Personal Information through third-party websites and services. The Services may enable you to share directly Personal Information with websites or online services operated by third parties. For example, the Services contain links to third-party websites that incorporate comment and social media features. The Services may also contain a Facebook “like” button, an Instagram “follow” button, a YouTube “subscribe” button, or similar features. If you choose to use these features, you may disclose your Personal Information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by Waggle Mail, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your Personal Information will be subject to the privacy policies of the third-party websites or services, and not this Policy.
Aggregated and de-identified information. From time to time, Waggle Mail may also share aggregated or de-identified information that cannot reasonably identify Services users or the devices they use, such as by publishing a report on trends in the usage of the Services.
YOUR CHOICES AND RIGHTS
Waggle Mail provides you with a variety of choices regarding how we use Personal Information and how you can manage our privacy when you use the Services, more particularly set out as follows:
- Account Updates, Deletions and Deactivations: To update your Account, profile settings, disable or deactivate your Account and/or close your Account, please log into your Account and modify its settings on your Account. You may also contact our Privacy Officer to assist with these matters.
- Access to Information: We recognize that you may have the right to access your Personal Information. Any access request must be made to the Privacy Officer. We may charge a reasonable fee for providing information in response to an access request, and, upon request, we will provide an estimate of any such fee upon receiving a request to access information. We may require a deposit for all or part of the fee. Where applicable or permitted, we will make the information available within 30 days or provide written notice when we require additional time to respond to a request for access to information.
- Declining Personal Information: You may decline to share Personal Information with us, in which case, we may not be able to provide you some of the features and functionality found on the Services.
- Exclusions: In some situations, we may not be able to provide access to certain Personal Information as the right to access Personal Information is not absolute. If we do not provide you with the requested information, we will notify you in writing and explain our reason(s) for not fulfilling your request.
Note: deactivating your Account does not cause your Account information to be automatically deleted from our servers.
RIGHTS OF NON-CANADIAN RESIDENTS
Depending on where you live, you may have certain rights regarding your Personal Information. Please note that in some circumstances, we may need to keep processing your Personal Information for certain legitimate interest or to comply with legal obligations. If these rights apply, to you, they may permit you to request that we:
- obtain access to or a copy of certain Personal Information we hold about you;
- prevent the processing of your Personal Information for direct marketing purposes (including any direct marketing processing based on profiling);
- update Personal Information that is out of date or incorrect;
- delete certain Personal Information we hold about you;
- restrict the way that we process and disclose Personal Information about you;
- transfer your Personal Information to a third-party provider of services; and
- revoke consent that you previously provided for the processing of your Personal Information.
Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable laws. We may request you provide us with information necessary to confirm your identity (such as date of birth, IP address, and email address) before responding to your request.
If you want to update Personal Information which is out of date or incorrect, restrict the way that we process and disclose specific Personal Information about you or object to the processing of your Personal Information, then please submit your request by emailing our Privacy Officer.
If you are concerned about having cookies on your computer or device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer or device. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly. You can:
- Disable browser cookies: Your browser may allow you to control cookies, some of which may enable third parties to collect data about your use of our Sites. Instructions for blocking cookies on commonly used browsers can be found below. You must adjust the settings on each browser and on each device for which you wish to block cookies.
- Disable Flash cookies: To disable Flash cookies, follow these instructions. This setting will need to be adjusted on each device for which you wish to block Flash cookies.
- Exercise interest-based advertising opt-outs: Certain advertising groups allow consumers to opt-out of receiving interest-based advertising from their respective members. You can use the links below to opt out. You will need to exercise these opt-outs on each browser on each device for which you wish to opt-out.
- Limit mobile device interest-based advertising: You can adjust your advertising preferences on mobile devices through your device settings:
- iOS Devices: Go to Settings > Privacy > Advertising (at the bottom of the screen) > Turn on Limit Ad Tracking
- Android Devices: Go to Google Settings > Ads > Opt Out of Interest-Based Ads.
We take special precautions to comply with applicable laws regarding children’s advertising and privacy. The Waggle Mail Services are not directed to children under the age of 13, and Waggle Mail will never knowingly collect Personal Information or other information from anyone it knows is under the age of 13. If you think we have done this, please let us know. Persons over 13 but under 18 years of age may use the Services only in conjunction with and under the supervision of a parent or legal guardian.
For residents of the EEA and residents where the processing of Personal Information is based on consent, we will not knowingly engage in that processing for users under the age of consent established by applicable data protection laws. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove that information from our records.
MERGER OR SALE
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, then your Personal Information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Waggle Mail will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected.
INTERNATIONAL DATA TRANSFERS AND CLOUD COMPUTING
We process and store Personal Information using our server(s) based in Canada, but, on occasion or in the future, may also use cloud service providers. In such instances, we have ensured (or will ensure) that our service providers are bound to maintain the Personal Information in accordance with this Policy. By accepting this Policy or using the Services, you agree to the transfer of any Personal Information that you provide to such jurisdictions and cloud-based servers.
CHANGES AND UPDATES TO THIS POLICY
We may change this Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Policy to stay informed. Your continued use of the Services after posting such changes constitutes your binding acceptance of such changes. If we make changes that materially alter your privacy rights, we will provide additional notice. If you disagree with the changes to this Policy, you should contact us at the contact information below.
Waggle Mail is responsible for Personal Information under its control and has designated a Privacy Officer who is accountable for this Policy and applicable Canadian and other privacy and data protection laws. For any questions, comments or suggestions regarding this Policy or the Personal Information protection practices of Waggle Mail not discussed in this Policy, you can contact our Privacy Officer by email or regular mail at the coordinates below. You can submit complaints to our Privacy Officer if you think that we are not meeting our obligations with respect to the protection of Personal Information. We will investigate such complaints and, if they are justified, will take appropriate measures to correct the situation. If you are not satisfied with this internal review of your complaint, you can contact the Office of the Privacy Commissioner of Canada.
Waggle Mail’s Privacy Officer may be contacted at:
Attention: Privacy Officer
Phone: (888) 924-4364 or (888) WAG-4DOG
E-mail: [email protected]