At Hart Stores Inc. Companies Limited and its subsidiaries and divisions, the protection of personal information has always been of great importance. Hart Stores Inc. is committed to maintaining the accuracy, confidentiality, integrity and security of your personal information. This Privacy Code is based on the requirements of the Personal Information Protection and Electronic Documents Act (“PIPEDA”), as well as applicable provincial privacy laws and is part of our commitment to ensuring that personal information in our possession is protected and is only collected, used and disclosed in accordance with applicable laws.

What is personal information?

Personal information is any information about an identifiable person, other than certain business contact information. It can include such things as a person’s home address, date of birth, social insurance number, medical and financial information. The type of personal information that is collected from you also depends on the nature of the transaction. Here are some examples of the type of personal information we collect, use and/or disclose:

Retail:In stores, Hart Stores Inc. will collect and use such personal information as is necessary to process your transaction, including verifying your identity when required. You may be asked to provide personal information when returning products which information is only used for the protection of Hart Stores Inc.’s business.

Online:Hart Stores Inc. asks for your name, address, email address, and other personal information when you create an account online. You will also be asked for personal information when you make a C.O.D. order (so that we can process your order), and if your personal information is to be used for other purposes, your consent will be obtained.

Privacy Principles

1. Accountability

Hart Stores Inc. is responsible for personal information under its control, including any personal information disclosed to third parties for handling or administrative purposes. Hart Stores Inc. has designated a national Privacy Officer and other privacy officers at the local, area, subdivision or division specific level, who are accountable for Hart Stores Inc.’s compliance with this Privacy Code, with any Privacy Policy that applies to you and with privacy legislation.

2. Identifying Purposes

The purpose for which personal information is collected will be identified by Hart Stores Inc. at or before the time the information is collected, unless such purposes are obvious. When we intend to use your personal information for a purpose not identified to you when the information was collected, we will identify the new purpose to you prior to use. With your consent, we collect personal information about you for various purposes, including the following:

To verify your identity and protect each party from error and fraud

To verify your eligibility for, and to provide you with, products and services

To track and analyze your use of products and services (including the number of transactions by type, product code information, brand, etc.), shopping patterns, and the channels you use to obtain those products and services, to help us serve you better, and to provide you with information about other products and services which Hart Stores Inc. believes may be of interest to you

To manage and develop Hart Stores Inc.’s business and operations

To generate statistics and aggregate reports for internal use

To meet legal and regulatory requirements

To fulfill any other purpose set out in the Privacy Policy of any subsidiary or division of Hart Stores Inc. Companies Limited that applies to you.

3. Consent

Hart Stores Inc. will only collect, use or disclose your personal information with your knowledge and consent, except where otherwise required or permitted by law. Consent means voluntary agreement to the collection, use and disclosure of personal information for defined purposes. Hart Stores Inc. will not, as a condition of the supply of a product or service, unreasonably require you to consent to the collection, use or disclosure of information beyond what is required in the circumstances. The way in which consent is obtained may vary depending on the circumstances and the type of personal information involved.

Consent may be express (given orally, electronically or in writing) or implied (provided by an action or inaction), and can be provided directly by you or by an authorized representative. For instance, when you order products for delivery, certain basic information will be collected from you and this also will constitute implied consent for Hart Stores Inc. to use that information for the purpose of processing your order and delivering the items. Refusal or Withdrawal of Consent: You may refuse to consent or you may withdraw your consent to the continued collection, use or disclosure of your personal information or tell us that you do not wish to receive any marketing communications from us at any time on sufficient notice to Hart Stores Inc..

We will do our best to accommodate your request, subject to legal or contractual restrictions, current industry standards and our technical abilities. Your withdrawal of consent may result in Hart Stores Inc. becoming unable to provide or continue to provide you with certain services, products or benefits, and in such case you will be given notice of the implications of the withdrawal of your consent so that you can make an informed decision. Due to printing and distribution schedules, you may continue to receive some communications that were in the process before we received your request. If you have a product or service with a subsidiary or division of Hart Stores Inc. Companies Limited or with a co-venturer, you also may have to refuse to consent or withdraw your consent with that subsidiary, division or co-venturer.

4. Limiting Collection

Hart Stores Inc. will only collect, use or disclose your personal information with your knowledge and consent, except where otherwise required or permitted by law. Consent means voluntary agreement to the collection, use and disclosure of personal information for defined purposes. Hart Stores Inc. will not, as a condition of the supply of a product or service, unreasonably require you to consent to the collection, use or disclosure of information beyond what is required in the circumstances. The way in which consent is obtained may vary depending on the circumstances and the type of personal information involved. Consent may be express (given orally, electronically or in writing) or implied (provided by an action or inaction), and can be provided directly by you or by an authorized representative. For instance, when you order products for delivery, certain basic information will be collected from you and this also will constitute implied consent for Hart Stores Inc. to use that information for the purpose of processing your order and delivering the items. Refusal or Withdrawal of Consent: You may refuse to consent or you may withdraw your consent to the continued collection, use or disclosure of your personal information or tell us that you do not wish to receive any marketing communications from us at any time on sufficient notice to Hart Stores Inc..
We will do our best to accommodate your request, subject to legal or contractual restrictions, current industry standards and our technical abilities. Your withdrawal of consent may result in Hart Stores Inc. becoming unable to provide or continue to provide you with certain services, products or benefits, and in such case you will be given notice of the implications of the withdrawal of your consent so that you can make an informed decision. Due to printing and distribution schedules, you may continue to receive some communications that were in the process before we received your request. If you have a product or service with a subsidiary or division of Hart Stores Inc. Companies Limited or with a co-venturer, you also may have to refuse to consent or withdraw your consent with that subsidiary, division or co-venturer.

5. Limiting Use, Disclosure and Retention

Personal information will not be used for purposes other than those for which it was collected without your consent.
Hart Stores Inc. may disclose your personal information, including as follows:

With your consent;

To carefully select third party service providers that perform services for us or on our behalf and that we have confirmed use security and privacy standards comparable to ours;

To help us collect a debt or enforce an obligation owed to us by you; or

As otherwise required or permitted by law.

Personal information will be retained only as long as reasonably necessary for the fulfillment of the purposes for which it was collected or as required by law. All destruction or removal of personal information from our records is done securely with a due regard to the sensitivity of the information concerned. Hart Stores Inc. will not sell, trade, rent or lease your personal information to any organization, for any purpose.

6. Accuracy

Hart Stores Inc. will make reasonable efforts to ensure that personal information of individuals is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used, but we also rely on you to provide us with any changes to your personal information, and in particular to your contact information.

7. Safeguards

Hart Stores Inc. uses security measures appropriate to the sensitivity of the information in order to protect personal information in any media and format against loss or theft and against unauthorized access, disclosure, copying, use or modification.

8. Individual Access

Upon receipt by Hart Stores Inc. of your written request, you will be informed, within a reasonable time following such request, of the existence, use and disclosure of your personal information and will be given access to that information. Hart Stores Inc. will need to verify your identity before providing you with the personal information we hold about you.

If you have a disability, then upon request, we will make reasonable accommodations to provide you with your personal information in an alternative format. Hart Stores Inc. may not be able to provide you with access to your personal information where the information cannot be disclosed for reasons of security or commercial confidentiality, where the information is protected by legal privilege or when access is prohibited by law.

If Hart Stores Inc. cannot provide access, Hart Stores Inc. will inform you of the reasons why access has been denied, except when Hart Stores Inc. is prohibited from doing so by law. Hart Stores Inc. may charge a reasonable fee to cover the cost of providing the information to you. If a fee is charged, Hart Stores Inc. will inform you of the approximate cost of providing the information to you prior to processing your request and will provide you with the opportunity to withdraw your request.

You may challenge the accuracy and completeness of the information and have it amended as appropriate.

9. Challenging Compliance

You may contact us with any questions, complaints or suggestions with respect to Hart Stores Inc.’s compliance with this Privacy Code. If a complaint is found to be justified, appropriate measures will be taken including, if necessary, amending our practices and procedures. Please see “Contact us” below.
Sponsored or authorized by Hart Stores Inc.), your personal information will be collected, used and disclosed in accordance with the information provided to you about the contest.

A note about our website

When you visit our website, you do not have to provide us with any personal information. However, certain non-identifying information may be collected automatically. We do not consider this information to be personal information.

For example, our web server may collect the internet protocol (“IP”) address and the name of the Internet Service Provider (“ISP”) associated with the computer from which you accessed the website, the type and version of the web browser and operating system that you are using, and the address of the website that you visited prior to our website. If your web browser is configured to accept cookies, either temporary cookies (which remain on your system until you exit your current browser window) or permanent cookies (which remain on your system until you manually disable or delete the cookie using your browser software) may be placed on your computer.

A “cookie” is a small piece of information that our web server automatically sends to your browser for storage on your computer, which then permits our web server to recall information about your settings (such as the settings of your web browser and language preference) as a part of the anonymous information. Please note that portions of our website will not function if you do not accept cookies.

For your convenience, our website may contain links to other websites operated by third parties. Any such websites are wholly independent from our websites and we have no control over those websites and their operators, including their privacy policies and practices. Before providing any of your personal information on any such other website, you should review their policies on privacy and security.