This policy applies to Gaggi Media Communication Inc.’s (“Gaggi Media”) collection, use, storage and disclosure of information by Gaggi Media on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various third party websites, and (c) to Gaggi Media Other Information collection, including the purchase or acquisition of customer information from third parties. Gaggi Media is not responsible for the information collection or privacy practices of third party web sites or applications. Gaggi Media has drafted this policy to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
Collection of Personal Information
1. Survey Information. Gaggi Media and its vendors, who are hired to perform services on behalf of Gaggi Media (“Vendors”), collect information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a Gaggi Media survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Websites, and related technologies, and “offline” means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, Gaggi Media or a third party (a “Third Party”) may ask an individual to provide various information to Gaggi Media, which may include his or her name, email address, street address, postal code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, “Survey Information”). Gaggi Media may also collect information concerning an individual from another source and use that information in combination with information provided from the Websites. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to Gaggi Media or a Third Party, but an individual may receive incentives from Gaggi Media or a Third Party in exchange for providing Survey Information to Gaggi Media.
2. Third Party Information. Gaggi Media collects information from individuals when an individual provides information to a third party and Gaggi Media subsequently purchases, licenses, or otherwise acquires the information from the third party (the “Seller”), such as through participation in the Third Party’s loyalty rewards program. Such purchased or acquired information may include, but is not limited to, an individual’s name, email address, street address, postal code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, credit card information, education and marital status, occupation, member points balance, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, “Third Party List Information”). When acquiring Third Party List Information, Gaggi Media seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to Gaggi Media and that the Seller has a right to provide offers from advertisers to the individuals whose personal information is included on the Seller’s list.
3. Other Information. Other occasions when Gaggi Media obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Gaggi Media or by a third party, (2) when an individual requests assistance through Gaggi Media’s customer service department, and (3) when an individual voluntarily subscribes to a Gaggi Media service or newsletter (together, “Other Information”).
4. Cookies, Web Beacons, and Other Info Collected Using Technology (“Technology Information”).
a. Cookies. A cookie is a small amount of data stored on the hard drive of the individual’s computer that Vendors of Gaggi Media may use from time to time. This allows the Vendor to identify the individual with his or her corresponding data that resides in their database. Gaggi Media insists that Vendor cookies, if used, are compliant with all applicable privacy laws.
b. Web Beacons. A web beacon is programming code that can be used to display an image on a web page, but can also be used to transfer an individual’s unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows Gaggi Media’s Vendors to track certain websites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes.
c. New Technology. The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is Gaggi Media’s use of new and evolving technology. As a result, Gaggi Media STRONGLY ENCOURAGES INDIVIDUALS TO REVISIT THIS POLICY FOR ANY UPDATES REGARDING ITS USE OF TECHNOLOGY.
d. Outside Information. Gaggi Media may receive information about individuals from third parties or from other sources of information outside of Gaggi Media including information located in public databases (“Outside Information”).
e. Individual Information– As used herein, Individual Information means Survey Information, Third Party Information, Technology Information, and Outside Information, and any other information Gaggi Media gathers or receives about individuals.
f. No Information Collected from Children. In compliance with the Children’s Online Privacy Protection Act (“COPPA”) , Gaggi Media will never knowingly collect any personal information about children under the age of 13. If Gaggi Media obtains actual knowledge that it has obtained personal information about a child under the age of 13, the information will immediately be deleted from our database. Gaggi Media does not collect such information and therefore does not disclose such information to third parties.
5. Vendors. Gaggi Media may hire Vendors to assist it in providing services to its clients. Gaggi Media requires its Vendors to abide by all applicable laws, including PIPEDA, as a condition of working with Gaggi Media.
Use of Individual Information
6. Discretion to Use. Gaggi Media MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN ITS SOLE DISCRETION. The following paragraphs describe how Gaggi Media currently uses Individual Information, but Gaggi Media may change or broaden its use at any time. As noted above and below, Gaggi Media may update this policy from time to time. Gaggi Media and its Vendors may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and other digital or physical advertising opportunities, among other possible uses. If you do not wish us to use personal information about you to promote or sell our products and services or to sell, transfer or otherwise provide personal information about you to third parties, please inform us by contacting customer service at email@example.com and we will honour your request.
7. Email. Gaggi Media may use Individual Information to provide promotional offers by email to individuals. Gaggi Media may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list.
a. Email Content– In certain commercial email messages sent by Gaggi Media, an advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to Gaggi Media. The “Subject:” line of Gaggi Media email messages will usually contain a line provided from the advertiser to Gaggi Media.
b. Solicited Email– Gaggi Media only sends email to individuals who have agreed on the Websites to receive email from Gaggi Media or to individuals who have agreed on third party websites to receive email from third parties such as Gaggi Media. Gaggi Media does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Gaggi Media’s email messages.
8. Targeted Advertising. Gaggi Media and its Vendors use Individual Information to target advertising to an individual. When an individual is using the Internet, Gaggi Media and Vendors use Technology Information to associate an individual with that person’s Individual Information, and attempt to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. Gaggi Media or its Vendors may, in their discretion, target advertising by using email, direct mail, telephones, cell phones, banner ads and other means of communication to provide promotional offers. Gaggi Media and its Vendors may use Individual Information to advertise to individuals through telephones, cell phones, direct mail and telemarketing, but only to the extent this permitted by applicable laws.
9. Use of Technology Information. Gaggi Media and its Vendors use Technology Information (1) to match a person’s Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person’s online browsing habits on the Internet, (3) to determine which areas of applicable web sites are most frequently visited. This information helps Gaggi Media and Vendors to better understand the online habits of individuals so that they can target advertising and promotions to them.
10. Individual Profiles. Gaggi Media and its Vendors may use Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.
11. Storage of Individual Information. Gaggi Media or its Vendors, where relevant, store the Individual Information in a database on their computers. These computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Gaggi Media or Vendors’ control. Notwithstanding such measures, Gaggi Media or its Vendors cannot guarantee that its security measures will prevent computers from being illegally accessed, and the Individual Information on them stolen or altered.
Dissemination of Individual Information.
12. Sale or Transfer to Third Parties. Gaggi Media MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY LEGAL PURPOSE IN GAGGI MEDIA’S SOLE DISCRETION. If you do not wish us to use personal information about you to promote or sell our products and services or to sell, transfer or otherwise provide personal information about you to third parties, please inform us by contacting customer service at firstname.lastname@example.org and we will honour your request.
13. Legal Process. Gaggi Media may disclose Individual Information to respond to appropriate legal requests.
14. Direct Mail and Telemarketing. Gaggi Media and its Vendors use Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
15. Summary Data. Gaggi Media may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
16. Access. Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting customer service at the number on the order page. Gaggi Media may also grant advertising clients and email services providers access to an individual’s email address to verify the origin of the Individual Information collected.
Privacy Practices of Third Parties.
17. Advertiser cookies and web beacons. Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. Gaggi Media does not control Advertisers’ use of such technology and Gaggi Media has no responsibility for the use of such technology to gather information about individuals.
18. Links. The Websites and email messages sometimes contain hypertext links to the web sites of third parties. Gaggi Media is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by third parties. Such links are provided for your convenience and reference only. Gaggi Media does not operate or control in any respect any information, software, products or services available on such third party web sites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
19. Affiliated Companies. Gaggi Media may disclose, transfer, and sell Individual Information to entities affiliated with Gaggi Media in Gaggi Media’s discretion.
20. Business Transfers. As we continue to develop our business, we might sell or buy subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the customer consents otherwise).
If you wish to discontinue receiving email messages from Gaggi Media, use the unsubscribe procedure contained in the email or please write to:
Head Office Address:
2200 Yonge Street, Suite 1711
Canada M4S 2C6
How you can contact us