The ten (10) principles that make up the Personal Information Protection Policy (hereinafter the “Policy”) should be read in conjunction with accompanying notes.
This Policy applies to Adonis Group Inc. and Phoenicia Group Inc. their subsidiaries, corporate stores and franchised stores that offer various food, retail and wholesale services (hereinafter “Adonis”).
This Policy applies to the Personal Information that Adonis collects, uses or discloses regarding any of its Customers.
This Policy applies to the management of Personal Information be it in verbal, written or electronic form.
This Policy does not apply to the Collection, Use or Disclosure of Personal Information that is available to the public and that Adonis obtained without using special means, such as:
This Policy complies with the ten (10) principles set out in the Model Code for the Protection of Personal Information provided in the Personal Information Protection and Electronic Documents Act.
“Chief Privacy Officer” means an individual or individuals at Adonis who are in charge of ensuring compliance with and application of this Policy.
“Collection” means the act of collecting, acquiring or obtaining Personal Information in any way or by any means whatsoever, including from a Third Party.
“Consent” means the freely given agreement to the Collection, Use and/or Disclosure of Personal Information for the purposes specified by Adonis. Consent may be express or implied, and may be given directly by the person or by that person’s authorized agent. Express Consent may be given orally, electronically or in writing. However it must always be clear. Implied Consent refers to Consent that can be reasonably inferred from a person’s action or inaction.
“Customer” means an individual who (i) buys or orders products or services at or from a store under any banner of Adonis; (ii) corresponds with Adonis; (iii) enters a promotional contest organized by Adonis; (iv) is a member of any program or website offered by Adonis; or (v) accesses any other customer service offered by Adonis.
“Disclosure” means the act of revealing Personal Information to a Third Party.
“Personal Information” means any information about a Customer that can be used to identify that Customer, including, but not limited to, the Customer’s name, addresses, email addresses, date of birth, credit information, Adonis program or application member number.
“Third Party” means a person other than a Customer, Adonis or an agent of Adonis.
“Use” means Adonis’ processing, handling and management of Personal Information.
2.1 Adonis Collects Personal Information for the following purposes:
2.2 Adonis shall use its best efforts, as part of any Collection, to inform all persons concerned, electronically, verbally or in writing, of the purposes of said Collection of Personal Information. The persons Collecting the Personal Information shall explain, upon request, the purposes of the Collection or refer any person concerned to the appropriate department for an answer.
2.3 Subject to any legal provision to that effect, Adonis may not Use or Disclose Personal Information it Collects about a Customer for a new purpose without first identifying and recording said purpose and obtaining the Customer’s Consent.
2.4 Phone calls handled by Adonis may be recorded or monitored for quality control purposes. Closed circuit monitoring in Adonis stores and offices is conducted to ensure Customer, Third Party and employee safety and security.
3.1 For example, Adonis may Collect, Use or Disclose a Customer’s Personal Information without the Customer’s knowledge and Consent:
3.2 Adonis shall make reasonable efforts to ensure that the Customer is duly advised, when consenting to the Collection of his or her Personal Information, of the purposes for which it will be used or communicated. The purposes are to be stated clearly so that the Customer can understand them.
3.3 Typically, Adonis shall seek a Customer’s at the time of Collection of the Customer’s Personal Information. However, Adonis may seek this Consent after the Personal Information has been Collected, but must always obtain Consent before its Use or Disclosure for a new purpose.
3.4 For the purposes of this Policy, it is understood that a Customer’s purchasing products or using services constitute implied Consent to the Collection, Use and Disclosure of relevant Personal Information for the purposes identified by Adonis.
3.5 A Customer may withdraw Consent at any time, subject to legal or contractual restrictions and reasonable notice. A Customer may contact Adonis for information on the consequences of such withdrawal.
Adonis may also collect Personal Information from other sources, including credit bureaus if necessary in the treatment of the Customer’s request.
5.1 Adonis may also disclose Personal Information to:
5.2 Typically, Personal Information retained by Adonis is kept in Canada. In certain cases, Personal Information Collected by Adonis may be kept and processed in other countries for service provision purposes and may then be subject to the jurisdiction of these countries.
5.3 The only people to have access to Personal Information are those authorized by Adonis and whose duties require it.
5.4 Adonis retains Personal Information only so long as necessary for the identified purposes or as required by law. When access to the Personal Information is requested under this Policy, Adonis will retain either the Personal Information or the reasons for the decision long enough to allow the Customer to access said Personal Information or reasons.
5.5 Adonis shall establish controls, schedules and practices with respect to the retention and destruction or de-identification of Personal Information and files when they are no longer needed for the identified purposes or required by law.
Personal Information shall be as accurate, complete and up-to-date as possible.
6.1 Personal Information Used by Adonis must be as accurate, complete and up-to-date as possible to minimize the possibility that incorrect Personal Information may be Used.
6.2 Adonis shall update Personal Information only as required to satisfy the identified purposes or after receiving an update request from the Customer.
6.3 The Customer is responsible for updating his or her Personal Information by contacting Adonis as soon as reasonably possible and providing such updates to Adonis.
7.1 Adonis shall take reasonable steps to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification or destruction.
7.2 Adonis shall take reasonable steps to protect Personal Information Disclosed to Third Parties under contractual agreements that will state the confidentiality of the information and the purposes for which it is intended.
7.3 All persons authorized by Adonis to have access to Personal Information must respect the confidentiality of said information.
7.4 Adonis understands the importance of protecting Personal Information and uses Internet security protocols to safeguard Personal Information collected via the Internet. However, Customers must remember that the Internet is not a secure means of communication. Consequently, Adonis makes no representations or warranties as to the absolute security of Personal Information provided via the Internet. Customers acknowledge that they provide Personal Information to Adonis via the Internet at their own risk.
Furthermore, Adonis is in no way responsible for the Personal Information protection practices of other Internet websites that are neither owned nor controlled by Adonis but that are accessible from Adonis websites through links or hyperlinks.
7.5 Adonis takes reasonable steps to identify, contain and resolve breaches of security safeguards. In the event that Adonis considers that a breach of security safeguards creates a real risk of significant harm to an individual, Adonis will notify the relevant authorities and individuals in accordance with the conditions provided by applicable laws.
Adonis shall make readily available to individuals specific information about its management of Personal Information.
Adonis shall facilitate understanding of this Policy, namely by making the following information available upon request:
9.1 Upon request, Adonis shall give the Customer a reasonable opportunity to view the Personal Information in his or her file. The Personal Information must be provided or made accessible in a timely fashion, in a form that is understandable, and at reasonable cost to the Customer.
9.2 In certain situations, Adonis may refuse, in whole or in part, a Customer’s request for access to his or her Personal Information, particularly if:
Upon request, Adonis shall provide the reasons for denying access to the Personal Information.
9.3 Upon request, Adonis shall inform the Customer of the Use and Disclosure of the Personal Information and, when available, of the source of the information. As for a record of Disclosure of Personal Information, when Adonis cannot produce a list of the specific organizations to which it has Disclosed Personal Information about the Customer, it shall provide the list of those to which it may have Disclosed such information.
9.4 For the protection of the Personal Information, Adonis may require a Customer to submit a written request, with proof of identity, before informing the Customer of the existence, Use and Disclosure of his or her Personal Information and authorizing his or her access to his or her file.
9.5 Upon being advised of Personal Information that is deemed to be inaccurate or incomplete, Adonis shall promptly correct or complete it. Any disagreement as to the accuracy or completeness of a Customer’s Personal Information shall be recorded in the Customer’s file.
9.6 Any Customer may, via Adonis’ Customer Service Department, ask the Chief Privacy Officer for all or part of his/her Personal Information.
10.1 Adonis shall put procedures in place to receive and respond to complaints or inquiries about this Policy.
10.2 Adonis shall inform individuals of the existence of the complaint procedures and how to make a complaint.
10.3 The Chief Privacy Officer is accountable for the Policy’s application and may, at his/her sole discretion, seek advice from any person before providing a final response to any complaint.
10.4 Adonis shall review all Policy compliance complaints. If a complaint is found to be justified, Adonis shall take appropriate measures, including, if necessary and where reasonable, amending its Policy and practices. The complainant shall be informed of the steps taken regarding the complaint.
This Policy may be amended at any time at Adonis’ sole discretion without notice.
For more information on this Policy or on Adonis’ commitment to the protection of Personal Information, contact Adonis’ Customer Care Department at:
Adonis Group Inc.
Attention: Chief Privacy Officer
1595 Daniel-Johnson blvd., 4th floor
Laval, Québec, H7V 4C2