- the types of personal information we collect about you;
- the purposes for which we collect that information;
- how we use that information;
- with whom we share that information;
- how we safeguard that information;
- the choices available to you regarding how we use your personal information; and
- how you can contact us about our privacy practices.
Name of legal entity: Vector Corrosion Technologies Ltd. (incorporated and registered in Canada with registration number 86561 1677.)
Data privacy manager: Scott McCulloch
Postal Address: 474B Dovercourt Drive, Winnipeg, MB R3Y1G4
Telephone No: (204) 489-6300
- What personal information do we collect?
- What are the legal bases on which we process your personal information?
- What is the purpose of the collection and use of your personal information?
- To whom do we disclose your personal information?
- What if there is a change in the initial purpose for the collection of your personal information?
- Do we knowingly collect personal information about children?
- How do we safeguard your personal information?
- Do we transfer your personal information to third parties for storage or processing?
- How long do we retain your personal information?
- Do we collect, use, and disclose non-personal information about you?
- How do we ensure the accuracy of your personal information?
- What types of “cookies” and/or other technologies do we use and how can you change your “cookie” settings?
- Do we use third party advertising partners? If so, how can you opt out of targeted advertising?
- What type of analytics services do we use and for what purpose? How can you disable analytics?
- What are your rights in relation to your personal information?
- How do we handle complaints?
- How can you unsubscribe from our commercial electronic messages such as messages regarding new products or services?
“collection” means the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.
“disclosure” means making personal information available to a third party.
“non-personal information” means information that does not identify a specific individual and which we are unable to connect to other information in order to identify a specific individual.
“Organization” means a company, entity or organization, including any business, but does not include an individual.
“personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual.
“third party” means an individual other than the user, or the user's agent. It also means an organization other than Vector, or if the user is an organization, third party refers to an organization other than the user.
“use” means the treatment, handling and management of personal information by and within Vector.
“user” means an individual who visits the Sites and/or accesses the Service and/or uses the Service, as well as an Organization which visits the Sites and/or accesses the Services and/or uses the Service.
2. Personal Information We Collect
Personal Information You Provide To Us
You may provide us with your personal information in different ways. For example, we may collect any or all of the following personal information:
information that you provide when you complete forms on the Site or otherwise correspond with us (by whatever means), such as your name, company name, job title/role/position, email address, telephone number(s), postal address;
information about purchases you make including details of the purchase, bank information, billing address and shipping address;
information that you provide to Vector when you subscribe to our newsletter including your name and email address;
your correspondence with Vector employees or independent contractors, including any feedback, questions, concerns or comments you may have about the Service or problems that you report and including any responses you complete in respect of surveys or questionnaires;
comments, videos, photographs, and any other content or information that you may submit to us or the Site; and/or
details of your requests made through the Site or otherwise raised with us.
Technical Information We or Third Parties Collect Automatically
When you visit the Site or interact with our newsletters, we or third parties (such as Google, Youtube and Microsoft) may collect, using electronic means, technical information. This information may include:
- the IP address of your computer and which browser you use, including browser plug in type and version;
- operating system and operating platform;
- resolution of screen;
- location and time zone setting;
- language settings in browsers;
- the site you came from and searched for keywords if arriving from a search engine; and/or
- your interactions with our Site and/newsletter, including what you click on.
This technical information (some of which in certain instances may be considered personal information) is aggregated and used to measure and improve effectiveness of our Site. We do not attempt to combine this technical information with other personal information we collect.
Special Categories of Personal Information
We do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. Legal Basis for Processing Your Personal Information
Below are the types of lawful basis that, depending on the circumstances, we may rely on to process your personal information:
Legal Basis for Processing
Explanation of Legal Basis
You have given express consent to us for the processing of your personal information for one or more specific purposes.
Performance of a Contract
Processing your personal information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a Legal or Regulatory Obligation
Processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject.
Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal basis we are relying on to process your personal information.
4. Purpose of Collection and Use of Personal Information
Vector collects your personal information and will use your personal information as is reasonably required for the following purposes:
- to provide the Service, and/or the other products/services or information that you request;
- to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information;
- to respond to feedback, questions, comments, requests, or complaints that you submit to Vector;
- to register you or an organization you work for as a new customer;
- to process, manage and deliver orders;
- to manage payment and charges for our products and services, including to collect and recover money owed to Vector;
- to allow you to leave reviews or feedback or to ask you and allow you to take part in surveys and competitions;
- to track communications with you;
- to analyze use of the Site and to improve the Site;
- to send emails, newsletters, regular mail or other communications from Vector;
- to make suggestions about products/services you may be interested in;
- to aggregate your personal information resulting from the combination and/or aggregation of certain raw personal information collected from you with other data in a way that no longer personally identifies you;
- to display advertising on the Site or to manage and serve our advertising on other sites. See Section 15 on targeted advertising and how you may opt out;
- to fulfill a purpose that we disclose to you when we request your personal information;
- to meet legal and regulatory requirements;
- to make suggestions and recommendations to you about goods or services that may be of interest to you (and see Section 15 for more details on targeted advertising); and/or
- to administer and protect Vector’s business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
Your personal information will only be collected and used by Vector and employees, independent contractors, agents, partners and service providers in a manner consistent with the activities of Vector. Access to your personal information by Vector employees, independent contractors, agents, partners and service providers is limited only to those authorized, based on their need to deal with the personal information for the reason(s) for which it was obtained, including to enable them to perform a business, professional or technical support function for Vector.
If you fail to provide personal information
Where Vector needs to collect personal information by law, under the terms of a contract Vector has with you or in order to provide you with the Service, and you fail to provide that information when requested, Vector may not be able to perform the contract it has or is trying to enter into with you or may not be able to provide the Service to you. In this case, Vector may have to cancel a product or service but Vector will notify you if this is the case at the time.
5. Disclosure of Personal Information
Vector may disclose your personal information to:
- Vector’s employees and Vector partner companies, independent contractors that provide IT and systems administration services, agents and affiliated distributors, professional advisors including lawyers, bankers, auditors, and insurers, distributors, retailers, tax and government authorities, regulators fraud prevention agencies as is reasonably necessary to enable these parties to perform a business, professional or technical support function for Vector;
- a person who, in the reasonable judgment of Vector, is seeking the information as your agent; and
- [a third party or parties, where you consent to such disclosure or the disclosure is permitted or required by law].
The parties mentioned above may be based in the UK, Canada or the US.
Vector requires all third parties to respect the security of your personal information and to treat it in accordance with the law. Vector does not allow its third-party service providers to use your personal information for their own purposes and only permits them to process your personal information or specified purposes and in accordance with Vector’s instructions.
Corporate Reorganization and Business Transfers
6. Change of Purpose
Vector will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and obtain your express consent to do so.
Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
8. Safeguarding Your Personal Information
Vector is committed to safeguarding your personal information. Vector uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, misuse, modification or destruction, and any other unlawful form of processing of the personal information in our possession regardless of the format in which it is held. The methods of protection and safeguards used by Vector include, but are not limited to:
- Administrative safeguards such as privacy and security policies and procedures, privacy and data protection training for Vector employees, independent contractors, and agents, and non-disclosure or confidentiality agreements;
- Technical safeguards such as security testing, vulnerability scans, and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks;
- Physical safeguards such as need-to-know access for Vector employees, independent contractors, agents, partners and service providers.
In any organization, failure to protect personal information can increase the risk of a privacy breach which can lead to things such as financial loss, reputational harm, fraud, or identity theft. While Vector cannot guarantee that a privacy breach will not occur, Vector will make every effort to prevent such occurrences by implementing the above security safeguards.
Vector has put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Vector also ensures that its employees, independent contractors, agents, partners and service providers with access to personal information are made aware of the importance of maintaining the confidentiality of personal information.
Vector takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.
While Vector is committed to safeguarding your personal information, we cannot ensure or warrant the security of any personal information we collect either directly or automatically from you, and you provide your personal information at your own risk.
Vector cannot guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal information is of a sensitive nature, in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.
Vector also cannot guarantee that information sent or received over the Internet is secure and does not make any representation or warranty concerning the security of personal information communicated to or from Vector via the Internet or regarding the interception by third parties.
9. Cross Border Transfer of Personal Information
Vector has measures in place to ensure that during cross-border transfers of your personal information the personal information is subject to appropriate safeguards in accordance with data protection laws. These measures typically include contractual safeguards stipulating the confidentiality of the information and the purposes for which it is to be used. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information.
Where and when appropriate, we will transmit amended personal information to third parties having access to the personal information in question.
10. Retention of Personal Information
To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
11. Non-Personal Information
Vector may collect, use and disclose non-personal information, including aggregated data resulting from the combination and/or aggregation or certain raw data collected from you with other data in a way that no longer personally identifies you. We make no attempt to link this non-personal information with the identity of individuals. We may permanently archive non-personal information for future use in any manner whatsoever.
12. Accuracy of Personal Information
Vector is committed to keeping your personal information as complete, up-to-date and accurate as is necessary for the purposes for which it is to be used. Vector will promptly correct or complete any personal information found to be inaccurate or incomplete. Where appropriate, Vector will transmit amended information to third parties having access to the personal information in question.
Please see Section 17 in relation to your legal rights relating to the accuracy of or the correction of personal information Vector holds about you.
It is important that the personal information Vector holds about you is accurate and current. Please keep Vector informed if your personal information changes during your relationship with us.
14. Links to Other Websites
15. Targeted Advertising and How You May Opt Out
We may use third party advertising partners such as advertising networks, exchanges, and social media platforms to display advertising on the Site or to manage and serve our advertising on other sites. You have a variety of options to opt out of interest-based advertising ranging from browser controls, add on utilities such as ad blockers, and other opt out tools. Opt out tools may include organizations such as:
- Network Advertising Initiative: https://optout.networkadvertising.org/?c=1;
- Digital Advertising Alliance (“DAA”) of Canada: https://youradchoices.ca/;
- DAA YourAdChoices: https://youradchoices.ca/en/tools;
- Your Online Choices: youronlinechoices.com/uk
The Site utilizes Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses "cookies," which are text files placed on your computer, to help the website analyze how users use the Site, compiling reports on the activity of the Site for the Site’s operators and providing other services relating to website activity and Internet usage. The information generated by the cookie (including the IP address) is transferred and stored on a Google server located in the United States.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other information held by Google.
We may also use additional analytics programs from time to time to process non-personal information about you, such as Microsoft Dynamics 365 and YouTube Analytics. Modern browsers will allow you to turn off or stop accepting the cookies that power these programs. Please remember that turning off some cookies may result in our site not working as intended.
We make no attempt to link this non-personal information with the identity of individuals using the Site. Non-personal information may be permanently archived for future use in any manner whatsoever by Vector.
Disable Google Analytics
You can prevent the collection and processing of cookie created data relating to your utilization of the Site (including your IP) via Google by downloading and installing the browser-plugin available under the following link (https://tools.google.com/dlpage/gaoptout?hl=en).
Google currently offers this opt-out tool for Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Edge.
Further information concerning the terms and conditions of Google’s use and data privacy can be found at https://www.google.com/analytics/terms/us.html or at https://policies.google.com/privacy.
17. Your Personal Information Rights
Under certain circumstances and in accordance with your country’s applicable data protection laws, you have the following rights:
Explanation of Right
Right of Access
The right to make a written request for details of your personal information and a copy of that personal information.
Right to Rectification
The right to have incomplete or inaccurate information about you corrected or removed.
Right to Erasure
('Right to be Forgotten')
The right to have some or all of your personal information erased where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Restriction of Processing
The right to request that your personal information is only used for restricted purposes. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
Right to Automated Decisions
The right to contest any automated decision made where such a decision is based solely on automated processing, including profiling, which produces legal effect concerning you or similarly significantly affects you, unless you have expressly consented to it or it is necessary for entering into, or performance of, a contract for the provision of services to you or otherwise authorized by applicable law.
Right to Object
The right to object to processing of your personal information in cases where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes.
Right to Data Portability
The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to Withdraw Consent
The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to help us respond efficiently to your request.
You will not have to pay a fee to access your personal information (or to exercise any of the above rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
In addition, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), Office of the Privacy Commissioner of Canada, the Canadian regulator for data protection issues (www.priv.gc.ca) or. We would, however, appreciate the chance to deal with your concerns before you approach a regulator so please contact us in the first instance.
19. Unsubscribe from Commercial Electronic Messages
We may send you commercial electronic messages (such as marketing or promotional messages) if you have:
- provided us with your express consent to receive these messages;
- recently purchased or leased a product or service from us;
- entered into a contract with us or some other form of business relationship with us;
- requested information from us; or
- applicable law otherwise permits us to send commercial electronic messages to you.
If you no longer wish to receive commercial electronic messages from Vector regarding our new products or services, promotions or other similar communications, you may unsubscribe here. Please note that, after you unsubscribe, Vector may still send electronic communications to you in certain limited circumstances, such as to provide you with service notifications and billing information, or to provide information that Vector is legally obligated to provide you.
Date: January 1, 2022