INTRODUCTION
At GardaWorld, we understand the importance of privacy and are committed to protecting your personal data. This Privacy Notice informs you of how we treat your personal data when you visit our website (regardless of where you visit from) and explains your privacy rights. GardaWorld has designed this Policy to meet the requirements of the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA"), the Act respecting the protection of personal information in the private sector (Quebec) ("PIPEDA") and to comply with the following ten privacy principles, as well as the General Data Protection Regulation (GDPR) and all other applicable laws.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
The purpose of this Privacy Notice is to inform you about how GardaWorld collects, discloses and uses your personal information when you use this site, including information you provide through this site when you sign up for our Newsletter or when you purchase a product or service.
This site is not intended for children and we do not knowingly collect data from children.
It is important that you read this Privacy Notice together with any other Privacy Notice or Fair Processing Notice that we may provide on certain occasions when we collect or process personal data about you so that you are fully aware of how and why we use your data. This Privacy Notice supplements the other notices and is not intended to replace them.
RESPONSIBLE
GardaWorld is made up of various legal entities, specific details of which can be provided on request. This Privacy Notice is published on behalf of the GardaWorld Group. Accordingly, when we refer to "GardaWorld", "we", "us" or "our" in this Privacy Notice, we are referring to the relevant company within the GardaWorld Group responsible for processing your data. GardaWorld Security Corporation controls and is responsible for this website.
We have appointed a data privacy manager (DPM) to oversee matters relating to this Privacy Notice. If you have any questions about this Privacy Notice, including any request to exercise your statutory rights, please contact DPM by e-mail at dataprotection@garda.com
For Quebec residents
If you prefer, you can contact our Privacy Officer by mail:
ATTN: Responsable de la protection des renseignements personnels
2300, rue Émile-Bélanger
Saint-Laurent (QC)
H4R 3J4
Other individuals within GardaWorld may be delegated to act on behalf of the DPM or to assume responsibility for the day-to-day collection or processing of personal data.
You have the right to lodge a complaint at any time with the competent authority responsible for data protection issues. However, we would like to have the opportunity to discuss your concerns with you before you discuss them with the competent authority. Please contact us first.
YOUR OBLIGATION TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes during the course of your relationship with us.
LINKS TO THIRD PARTIES
This website may include links to third-party websites, plug-ins and applications. By clicking on these links or activating these connections, third parties may collect or share data about you. We have no control over these third-party websites and are not responsible for their privacy statements. When you leave our Web site, we invite you to read the privacy notice of each Web site you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data or personal information means any information about a person that allows that person to be identified. It does not include data from which the identity has been removed (anonymous data).
We may collect, use, store and transfer various types of personal data about you, which we have grouped together as follows:
- Identity data: includes first name, maiden name, family name, user name or similar identifier, marital status, title, date of birth and gender.
- Contact information: includes billing address, delivery address, e-mail address and telephone numbers.
- Banking data: includes bank account and payment card information.
- Transaction data: includes information about payments you have received or made and other information about products and services you have purchased from us.
- Computer data: includes IP (Internet Protocol) address, your connection data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technologies on the devices you use to access this site.
- Profile data: includes your username and password, purchases and orders, interests, preferences, comments and survey responses.
- Usage data: includes information about how you use our website, products and services.
- Marketing and communications data: includes your preferences regarding the receipt of advertising from us and our third parties and your communications preferences.
We also collect, use and share aggregated data such as statistical or demographic data for serious and legitimate purposes. Aggregated data may be derived from your personal data, but it is not considered personal data because it is anonymized, meaning that it does not directly or indirectly identify you. For example, we may aggregate your usage data to calculate the percentage of users accessing a particular website feature. However, if we combine aggregated data with your personal data or link them so that they can directly or indirectly identify you, we treat the combined data as personal data, which is used in accordance with this Privacy Policy.
We do not collect any special or sensitive categories of personal data about you (this includes information about your race or ethnic origin, religious or philosophical beliefs, sex life and sexual orientation, political opinions, trade union membership, health information and genetic and biometric data). We also do not collect information on criminal convictions and offences.
IF YOU DO NOT PROVIDE PERSONAL DATA
Where we are required to collect personal data by law or under the terms of a contract we have entered into with you, and you fail to provide such data when requested by us, we may be unable to perform the contract we have entered into or are attempting to enter into with you (for example, to supply goods or services to you). In this case, we may have to cancel a product or service we provide to you, but we will inform you of this at the time. If withdrawing your consent necessarily involves terminating the contract between us, you understand that certain contractual consequences may apply.
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
We use a variety of methods to collect the data you provide to us or about yourself, including :
- Direct interaction. You may provide us with your identity, contact and financial information by filling out forms or by communicating with us by mail, telephone, e-mail or otherwise. This includes the personal data you provide when you :
- make a request for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request advertising; or
- send us a comment.
- Automated technologies or interactions. When you interact with our website, we may automatically collect technical data about your equipment, navigation and browsing patterns. We collect this personal data using cookies, server logs and similar technologies. We may also receive technical data about you if you visit other sites that use our cookies. Please see our Cookie Policy for more information.
- Third parties or publicly accessible sources. We may receive personal data about you from various third parties and public sources, such as those listed below:
a) Analytical data providers such as Google;
b) advertising networks;
c) providers of social networks and similar platforms; and
d) research information providers.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We only use your personal data where permitted by applicable law. Most often, we use your personal data in the following circumstances:
- If we need to perform the contract we are about to enter into with you or have entered into with you.
- If our legitimate interests (or those of a third party) or yours so require and fundamental rights do not override these interests.
- If we have to comply with a legal or regulatory obligation.
- For our activities in Quebec, consent is the only legal basis for processing your personal data, with some exceptions permitted by law.
We will obtain your consent to process your personal data for the purpose of sending you direct advertising communications from third parties by e-mail or text message. You have the right to withdraw your consent to the sending of advertisements at any time by contacting us at dataprotection@garda.com.
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We have set out below, in table form, a description of all the ways in which we plan to use your personal data.
Please note that we may process your personal data for more than one legitimate reason depending on the specific purpose for which we use your data. Please contact us if you require specific information about the legal basis on which we process your personal data.
Objective/Activity | Data type |
To register as a new consumer | a) Identity b) Contact details |
To process and deliver your order, in particular : a) Manage payments, fees and charges b) Collecting the money you owe us | a) Identity b) Contact details c) Bank details d) Operations e) Marketing and communications |
To manage our relationship with you, including : a) Inform you of any changes to our terms and conditions or Privacy Policy b) Ask you to leave a comment or answer a survey | a) Identity b) Contact details c) Profile d) Marketing and communications |
To enable you to take part in a survey | a) Identity b) Contact details c) Profile d) Use e) Marketing and communications |
To manage and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, communication and data hosting) | a) Identity b) Contact details c) Computer data |
To provide you with relevant website content and advertisements and to measure or understand the effectiveness of the advertising we provide to you | a) Identity b) Contact details c) Profile d) Use e) Marketing and communications f) Computer data |
To use data analysis to improve our website, products and services, marketing, customer relations and customer experiences | a) Computer data b) Use |
To make suggestions and recommendations on goods or services that may be of interest to you | a) Identity b) Contact details c) Computer data d) Use e) Profile |
MARKETING
We strive to offer you choices regarding certain uses of personal data, particularly in marketing and advertising. We have established the following personal data control mechanisms:
OUR PROMOTIONAL OFFERS
We may use your identity data, contact data, computer data, usage data and profile data to form an opinion about what you want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you (what we call marketing).
You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, or provided us with your contact information when you signed up for a promotion or service and if, in each case, you do not opt out of receiving such marketing.
THIRD-PARTY MARKETING
We will obtain your express consent before sharing your personal data with any company outside the GardaWorld group of companies for marketing purposes.
EXCLUSION OPTION
You may ask us or third parties to stop sending you marketing messages at any time by logging on to the Site and checking or unchecking the appropriate boxes to adjust your marketing preferences or by following the unsubscribe links included in any marketing message sent to you or by contacting us at any time.
When you choose not to receive these marketing messages, this does not apply to personal data provided to us as part of a product or service purchase, warranty registration, product or service experience or other transactions.
WITNESSES
You can set your browser to refuse all or certain cookies, or to alert you when Web sites set or access cookies. If you disable or refuse cookies, please note that some parts of this site may become inaccessible or may not function properly. For more information on the cookies we use, please see our Cookie Policy.
CHANGE OF OBJECTIVE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for purposes unrelated to the purpose, we will inform you and explain the legal basis for doing so.
Please note that we may process your personal data without your knowledge or consent, in accordance with the aforementioned rules, where required or permitted by applicable law.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may need to share your personal data with the parties listed below for the purposes set out in the table in provision 4.
- Internal third parties as defined in the Glossary.
- External third parties as defined in the Glossary.
- Third parties to whom we choose to sell or transfer our business or assets, or with whom we decide to merge parts of our business or combine our assets. In addition, we may seek to acquire or merge with other businesses. If there is a change in our business, the new owners may use your personal data in the same way as set out in this Privacy Notice.
6. INTERNATIONAL TRANSFERS
We share your personal data within the GardaWorld Group. This means the transfer of your data within and outside the European Economic Area (EEA). Also, if you are a data subject subject subject to PIPEDA in Quebec, you understand that it is possible that your personal data may be hosted outside Quebec, either by being communicated within the GardaWorld group or by being communicated to a third party within a category of third parties identified in this policy that would have its servers outside Quebec.
We ensure that your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
Whenever we transfer your personal data outside the EEA, we will ensure, as far as is reasonably possible, that they benefit from a similar degree of protection.
7. DATA SECURITY
We have implemented appropriate security measures to prevent your personal data from being accidentally lost or used, accessed, modified or communicated in an unauthorized manner. In addition, we restrict access to your personal data to employees, agents, contractors and other third parties who need to know it for business purposes. They will only process your personal data in accordance with our instructions and are subject to an obligation of confidentiality. Despite these measures, you understand that it is impossible to guarantee that we will not be the victim of a confidentiality incident affecting your personal data.
We have procedures in place to deal with any suspected personal data breach and will notify you and any relevant regulatory body of a breach if we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU STORE MY PERSONAL DATA?
We will retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including any retention requirements under applicable law.
In determining the appropriate retention period for personal data in accordance with the specific purposes for which it was collected, we take into account the amount, the nature of the sensitivity of the personal data, the potential risk of harm arising from the unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the possibility that we may achieve those purposes by other means, as well as applicable legal requirements.
Under certain circumstances, you can ask us to delete your data: see below for more information.
In certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.
9. YOUR LEGAL GUARANTEES
In some cases, you have rights under data protection laws in relation to your personal data concerning the following:
- Request for access to your personal data
- Request for correction of your personal data
- Request for deletion of your personal data
- Opposition to the processing of your personal data
- Request to restrict the processing of your personal data
- Request for transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the above rights, please contact your designated DPM for further information.
NO USUAL FEES
There is no charge for accessing your personal data (or for exercising any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Furthermore, we may refuse to comply with your request in such circumstances.
WHAT WE MAY NEED TO ASK YOU
We may need to ask you for specific information to help us confirm your identity and guarantee your right to access your personal data (or to exercise one of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who does not have the right to receive it. We may also contact you to request further information regarding your request in order to expedite our response.
10. SUMMARY OF OUR PRACTICES IN PERSONAL DATA GOVERNANCE
GardaWorld is committed to protecting your personal information throughout its life cycle in accordance with its privacy practices and in compliance with the requirements of applicable laws.
To this end, in addition to our privacy policy, GardaWorld has adopted an internal data governance policy that sets out the principles governing the protection of personal data in the context of its operations.
The objectives of our internal governance policy are :
- to ensure that your personal data is processed in an appropriate, secure, compliant and transparent manner;
- establish guidelines for GardaWorld's handling of personal data throughout its life cycle; and
define the roles and responsibilities of the DPM and our staff.
1. Roles and responsibilities
Because respecting your personal data is everyone's business at GardaWorld, our DPM is supported by a team that is fully aware of personal data protection and the rights of those concerned.
Every member of our staff has a role to play in ensuring that we act in accordance with our data protection program. In fact, every member of our staff is called upon to :
- direct any questions or comments to DPM about how we process or should process your personal data;
participate in training and awareness-raising activities on the importance we attach to protecting personal data;
2 .Corporate governance guidelines
GardaWorld recognizes the importance of the protection, confidentiality and security of the personal data it processes in the course of its activities, and of making its employees and partners aware of this.
GardaWorld has prepared best practice and prohibited practice guidelines regarding how we may process your personal data, for example:
- we determine the purposes and objectives pursued before collecting your personal data. Thereafter, your personal data will only be used in accordance with these purposes.
- we seek to collect only the strict minimum in order to achieve the identified purposes.
- With respect to our activities in Quebec, we strive to obtain your consent at the time we collect your personal information, and where sensitive personal information is involved, we seek your express consent;
- we display our privacy policy in a clear and visible manner when we collect your personal information through a technological means;
- we ensure that our technological products or services with privacy settings offer the highest level of privacy by default, without any intervention on your part;
- we do not use technologies that allow identification, localization or profiling without disclosing this practice and informing you how to activate such features;
- we conduct Privacy Impact Assessments when required by law, and when we consider that processing your personal information involves risks to your privacy;
- To the extent possible, we restrict access to your personal information to those members of our staff and our service providers who need to have access to it in order to carry out our operations;
we do not share your personal information with third parties without your consent, except where permitted by law.
3. Confidentiality incidents
GardaWorld has implemented a process to respond to and handle privacy incidents.
Under this process, GardaWorld must take reasonable steps to reduce the risk of serious harm and review its practices to prevent similar privacy incidents in the future.
Garda documents all privacy incidents in its Privacy Incident Log and will adapt its privacy program as necessary following a privacy incident.
11. PERSONAL INFORMATION AGENT ACTIVITIES
Our subsidiary, Garda Security Group G.P. (hereinafter "GSG"), offers its clients research services concerning candidates, including background checks, credit investigations and reference checks. GSG thus holds personal information on individuals that will, in the course of these services, be communicated to GSG's clients. This personal information may include credit reports about the character, reputation and creditworthiness of the individuals to whom the information relates. We obtain such information from reputable third-party suppliers.
You have the right to access your personal information and, if it is inaccurate, to request that it be corrected by exercising these rights in the manner set out in Section 9 of this Notice. We will first validate your identity before processing your request. To consult your credit file, please write to us at the address identified in article 1 of this Notice. You will also find the contact details of our Privacy Officer in section 1.
We ensure that the personal information provided is current and accurate by including it as obtained from our service providers. We re-apply to our suppliers for each new customer request, using information obtained only a few days before it is sent to our customers. This communication to our customers is subject to a written contractual agreement that complies with the legal requirements in this respect, particularly as regards the security and confidentiality of this information. This information is kept confidential and secure and is subject to GSG and GardaWorld policies, processes and security measures. Access to this information is limited to those who require it by virtue of their position, and it is destroyed periodically.
12. GLOSSARY
LEGAL BASIS
Legitimate interest means our business interest in conducting and managing our business to enable us to offer you the best service or product and the best and safest experience. We ensure that we consider and balance any potential impact on you (positive and negative) and your rights to process your personal data for the purposes of our legitimate interests. We will not use your personal data for activities where the consequences to you outweigh our interests (unless we have obtained your consent or are otherwise required or permitted by law). You can find out more about how we assess our legitimate interests in relation to the impact on you of particular activities by contacting us.
Contract performance means the processing of your data where this is necessary for the performance of a contract to which you are a party or to take steps, where you so request, prior to entering into such a contract.
Compliance with a legal or regulatory obligation means processing your personal data where this is necessary to comply with a legal or regulatory obligation to which we are subject.
THIRD PARTY
INTERNAL THIRD PARTIES
Other GardaWorld group companies acting as joint controllers or processors and located in various international locations.
EXTERNAL THIRD PARTIES
- Service providers acting as data controllers.
- Professional advisors acting as joint controllers or processors, including lawyers, bankers, auditors and insurers providing consulting, banking, legal, insurance and accounting services.
- Regulatory authorities and other authorities acting as joint controllers or processors who require the declaration of processing activities in certain circumstances.
YOUR LEGAL GUARANTEES
You have the right to do the following:
Request access to your personal data (commonly referred to as a "data access request"). This allows you to receive a copy of the personal data we hold about you and to check that we are processing it legitimately.
Request the correction of any personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of any new data you provide.
Request the deletion of your personal data. This allows you to ask us to delete or withdraw personal data when we have no valid reason to continue processing it. You also have the right to ask us to delete or withdraw your personal data if you are successful in exercising your right to object to processing (see below), if we have processed your information unlawfully or if we are required to delete your personal data to comply with local law. Please note, however, that we may not always be able to accept your request for deletion for specific legal reasons, which will be notified to you, where applicable, at the time of your request.
To object to the processing of your personal data where we rely on a legitimate interest (or that of a third party) and your particular circumstances prompt you to object to the processing on the basis of this ground, as you consider that it adversely affects your fundamental rights and freedoms. You also have the right to object if we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate grounds for processing your information that override your rights and freedoms.
Request the restriction of the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following cases: a) if you want us to establish the accuracy of the data; b) when our use of the data is unlawful, but you do not want us to delete it; c) if you need us to retain the data, even if it is no longer necessary for us, because you need to formulate, assert or contest legal claims; or d) you have objected to our use of your data, but we need to verify whether we have legitimate and compelling reasons to use it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party chosen by you, with your personal data in a structured, commonly used and machine-readable format. Please note that this right only applies to automated information that you have initially authorized us to use, or if we have used this information to enter into a contract with you.
Withdraw your consent at any time where we rely on your consent to process your personal data. However, this will not affect the legitimacy of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will notify you if this is the case at the time you withdraw your consent.
Changes to the Privacy Policy
GardaWorld reserves the right to modify this Privacy Notice at any time, without notice, by posting the modified Privacy Notice on its website. Please check back frequently.