Crayola Privacy Policy
Updated and Effective as of Jan 5, 2022
Welcome
to Crayola Canada! We strive to help people create a caring and more
connected world, and to do this we use information collected from or
about you. This Policy describes the collection, use and sharing of
information, both online and offline, by Crayola Canada, a division of
William E. Coutts Company, Limited, and its family of companies
(“Crayola Canada,” “we,” “our,” or “us”)
through crayola.ca, crayolateachers.ca and any other website,
product, feature, or service we offer that posts or provides this policy
(collectively, the “Crayola
Canada Properties”). We may combine all of the information we collect
through our Crayola Canada Properties. By accessing or using the Crayola
Canada Properties, you agree that your access to and use are governed
by this Privacy Policy and our Terms of Use.
This
Policy regarding how personal information entrusted to us is collected,
used, disclosed, or retained reflects the principles set forth in
Canada’s Personal Information Protection and Electronic Documents Act, SC 2000, c 5.
CONTENTS
- Changes to This Privacy Policy
- General Audience Sites
- Consent for Personal Information
- Information We Collect
- How We Use Your Information
- How We Share Your Information
- Third-Party Advertising and Analytics
- Your Choices about the Information We Collect
- Your Rights and Access
- Security and Breach
- Retention
- Third-Party Content and Links
- Consent to Transfer
- Access, Questions, and Concerns
1. Changes to This Privacy Policy
To the extent allowed by applicable law, we reserve the right to change
this Privacy Policy at any time without prior notice. If we make
material changes to our Privacy Policy, we will update the effective
date and post a notice on our Crayola Canada Properties. We may also
provide notice to you in other ways, such as through contact information
you have provided, and provide you with the ability to opt-in or
opt-out of the changes as required by law. Your continued use of any of
the Crayola Canada Properties after the effective date of the revised
Privacy Policy will constitute your consent to those changes to the
fullest extent allowed by applicable law.
2. General Audience Sites
The Crayola Canada Properties are not intended for use by children under the age of 18. We do not knowingly collect personal information from children younger than age 18.
3. Consent for Personal Information
We collect information about you directly through the Crayola Canada
Properties, automatically when you visit the Crayola Canada Properties,
and sometimes from third parties. Some of the information we collect may
be considered “personal
information” under applicable laws. Personal information is any
information about an identifiable individual. Personal information
includes information that relates to personal characteristics (e.g.,
gender, age, income, home address, or phone number, ethnic background,
family status), health (e.g., health history, health conditions, health
services received), or activities and views (e.g. religion, politics,
opinions expressed by an individual, an opinion or evaluation of an
individual).
Note that we may de-identify your personal
information so as to make it non-personal, either by combining it with
information about other individuals and/or by hashing the information
or otherwise removing characteristics that make the information
personally identifiable to you. We will treat de-identified information
as non-personal to the fullest extent allowed by applicable law. If we
combine non-personal information with personal information, then we will
treat the combined information as personal information under this
Privacy Policy.
Crayola Canada collects and processes personal
information in accordance with this Policy. Crayola Canada collects,
uses, and discloses personal information for the purposes described in
this Policy, including providing our products, services, promotions, and
events to you. We will not sell, share, or rent this information to
others, except as set out in this Policy.
By providing Crayola
Canada with your personal information, you consent to the collection,
use, and disclosure of such information in accordance with this Policy
or for the purposes identified to you at the time you provided the
personal information. Any secondary use of the personal information will
only be processed with your express consent, except as required by law.
You
have the opportunity to withdraw your consent, or to opt-out at any
time. If you wish to withdraw your consent or to opt-out at any time,
including to remove yourself from our email or mailing list, please
contact us as set out in Section 15 below.
4. Information We Collect
Information you provide directly to us.
When you use
the Crayola Canada Properties, we ask you to provide us with certain
information. This information will depend on the Crayola Canada Property
you interact with, and may include without limitation:
- First and last name
- Email address, phone number and other contact information
- Shipping and billing addresses
- Demographic information, such as your date of birth and gender
- Account information
- Photographs,
video messages, handwriting, and other data provided by you as part of
a product review, question, or other user submission
- Wish list or other favourites information
- Information provided by you in responses to surveys, quizzes, or in community forums
- Information provided by you as you interact with our customer-support team
- Information provided by you as you provide feedback through the Crayola Canada Properties on our products or services
- Information
relating to transactions and products and services purchased, including
payment information, and return and exchange information
- Information relating to your application for employment with Crayola Canada
Information collected automatically.
We, our service providers, business partners, and/or other third
parties may automatically collect and/or store certain information when
you visit or interact with the Crayola Canada Properties (“Usage
Information”). This Usage Information may be stored and/or accessed
from your computer, tablet, mobile phone, or other device whenever you
visit or interact with the Crayola Canada Properties. Usage Information
may include, but is not limited to:
- Your IP address, mobile device identifier and other unique identifiers
- Device information, including device model, operating system version, device date and time, mobile network information
- Geolocation of your device
- How
you use and interact with the Crayola Canada Properties, including your
search terms, pages you visit, content you watch, and your preferences.
Usage Information may be collected through the use of the following technologies:
- Cookies and Local Storage.
Cookies and local storage are data files placed within a browser on
a device when it is used to visit the Crayola Canada Properties. Certain
web browsers and browser add-ons may provide additional local data
storage mechanisms. Cookies and local storage can be used for a variety
of purposes, including to store a unique identifier for your device that
recognizes your device as you visit the Crayola Canada Properties or
other websites or online services, and to remember your preferences.
Most browsers provide you with the ability to disable, decline, or clear
cookies and local storage; however, if you disable cookies you may find
this affects your ability to use certain parts of the Crayola Canada
Properties. For more information about cookies please visit https://www.aboutcookies.org.
- Web Tags. Small graphic images or other web programming code (also known as 1×1
GIFs or clear GIFs) may be included in our web pages and email
messages. These and similar technologies may be used for a number of
purposes, including to count visitors to the Crayola Canada Properties,
to monitor how users navigate the Crayola Canada Properties, to count
how many of our email messages were opened, or to count how many
particular products were viewed. The information we collect through this
technology may include the first date and time you open our e‑mail, and
whether you click any links included in our e‑mail.
- Embedded Scripts.
An embedded script is programming code that is designed to collect
information about your interactions with the Crayola Canada Properties,
such as the links you click on. The code is temporarily downloaded onto
your device from our server or a third-party service provider or
business partner, is active only while you are connected to a Crayola
Canada Property, and is deactivated or deleted thereafter.
Information from Third Parties.
We
may receive information about you from third parties, such as business
partners (including companies that assist us with online advertising and
analytics), other customers of the Crayola Canada Properties (such as
when they provide your information to send you one of our products),
data providers who enhance the information we have about you, and
sources of publicly available information.
Social Media.
We
may host or facilitate interactions with social media platforms, like
Facebook, Twitter, YouTube, Pinterest, and Instagram. When you interact
with social media through the Crayola Canada Properties, we will receive
information about you from the social media service and you will be
choosing to share information about your interactions with Crayola
Canada with that social media service.
In addition, the social
media service may set their own cookies and collect information about
your use of the Crayola Canada Properties, including your IP address or
other device identifiers, and which pages you visit on the Crayola
Canada Properties. These social media platforms may be able to collect
certain information on your visits to the Crayola Canada Properties
regardless of whether or not you affirmatively interact with the feature
and whether or not you are logged into (or have) an account with the
social media platform. If you are logged out or do not have an account
and visit a page with a social plug-in, your browser sends a more
limited set of information. Like other sites, the social media platform
will receive information about the webpage you are visiting, the date
and time of your visit, and other browser-related information. They may
use that information to help them improve their products or for other
purposes set forth in their privacy policy. We may also receive
information about you if other users of Social Media give us access to
their profiles and you are one of their connections or “friends.”
The
information we collect is subject to this Privacy Policy. The
information collected and stored by the third party remains subject to
the third party’s privacy practices, including, without limitation,
whether the third party continues to share information with us, the
types of information shared, and your choices with regard to what is
visible to others on that third-party website or service. The third
party may allow you to remove the application or feature, in which case
we will no longer collect information about you through the application
or feature, but may retain the information previously collected.
If you choose to post information to a third-party platform, that information may be public.
5. How We Use Your Information
We work hard to get to know you so that we can customize and personalize our services to you.
We
may use non-personal information for any purpose allowable by law,
including for advertising, research, and marketing purposes. We use
information collected from or about you, including personal information
and Usage Information, as disclosed in this Privacy Policy, including:
- Allowing
you to use and interact with the Crayola Canada Properties and the
features we offer, including processing your transactions, account
registration, and other features;
- Recognizing you across devices including in connection with online advertising;
- Identifying
your preferences, learning and anticipating your needs, and tailoring
our content, products, and services to you, including advertising,
recommendations, promotions, and offers we display to you, both online
and offline;
- Providing information on products/services we
think you may be interested in, including special offers and promotions
from us, our advertisers, and third-party partners;
- Responding to your requests for information and providing customer service;
- Verifying
your identity, including verifying that your email address is valid,
for purposes such as product reviews and fraud prevention;
- Improving our products, services, and marketing endeavours;
- For
internal business purposes, including operating the Crayola Canada
Properties, improving our products, services, and marketing endeavours,
and resolving technical issues reported about the Crayola Canada
Properties;
- Contacting you regarding your use of the services and, in our discretion, changes to our policies;
- Facilitating
your job search, processing your employment application, and preparing
related governmental and internal statistics reports;
- Complying
with the law and protecting the safety, rights, property, or security of
Crayola, the Crayola Canada Properties, consumers, and the general
public, including investigating and preventing fraud, illegal
activities, and activities that violate our policies;
- Upon notice to you at the time of collection or use of a feature, or otherwise with your consent.
6. How We Share Your Information
We may aggregate, de-identify, and/or anonymize any information such
that such information is no longer linked to your personal information.
We may share this non-personal information with third parties for any
purpose, for advertising, research and marketing purposes.
Personal
information submitted to Crayola Canada is kept confidential unless
disclosed in accordance with your express consent or legal requirements.
In any event, any personal information provided on any Crayola Canada
platform by a user is voluntary. Please note that revoking your consent
may result in not being able to access or utilize certain Crayola Canada
features, programs, or services.
Personal information provided by
Crayola Canada users will not be sold, shared, or rented to outside
organizations unless in accordance with your consent, except as
otherwise set out herein. Crayola Canada reserves the right to contact
any user at any time to forward information, respond to questions, or
provide notification of any changes to our services or our policies.
We
may share the information we have collected about you, including
Personal Information and Usage Information, as disclosed at the time you
provide us with information or your consent, and as described in this
Privacy Policy, including:
At Your Request and When You Post Content Publicly
.
We may share information when you direct us to do so. For example, you
may be presented with an opportunity to receive marketing offers from
a third party, or you may choose to write a product review, share a wish
list, ask a question, or engage with a social media service or
third-party application or feature, through which information about you
is shared. Please note that we are not responsible for the privacy
practices of third parties. If you later decide that you no longer want
to receive communications from a third party, you will need to contact
that third party directly.
In addition, we or a third-party social
networking or review platform, may offer features, such as message
boards and other public areas, where you can choose to interact with
others and/or submit content or post it publicly. Content that you post
may be viewed, collected, and used by others, and the protections of
this Privacy Policy will not apply.
Affiliated Third Parties.
We
may share your information with Crayola, LLC, and its and our parents,
affiliates, subsidiaries and divisions for business, analytical, and
operational purposes. Crayola Canada will ensure that any such recipient
only collects, uses, and discloses personal information in accordance
with its privacy policies, which will contain terms and conditions that
are at least as protective as those set forth in this Policy.
Sweepstakes, Contests and Promotions.
We may offer sweepstakes, contests, or other promotions (any of which, a “Promotion”)
that may require registration. By participating in a Promotion, you are
agreeing to the provisions, conditions, or official rules that govern
the Promotion, which may contain specific requirements of you
(including, except where prohibited by law, allowing the sponsor(s) of
the Promotion to use your name, voice, likeness, or other indicia of
persona in advertising or marketing materials). If you choose to enter
a Promotion, personal information may be disclosed to third parties or
the public in connection with the administration of such Promotion,
including in connection with winner selection, prize fulfillment, as
required by law, or as permitted by the Promotion’s terms or official
rules (such as on a winner’s list).
Employment Applications.
If
you apply for a job through the Crayola Canada Properties, we or our
service provider(s) may ask you to provide self-identifying information,
such as your name, address, phone number, and employment-related
information (such as that contained in a resume, cover letter, or
similar employment-related materials). Providing such self-identifying
information is voluntary, but if you do provide such information, we
and/or our service provider may submit that information to the
appropriate government or regulatory agencies to fulfill reporting
requirements and use that information to defend against
employment-related complaints. Please note that we may utilize a careers
portal that is operated by a third party, in which case, you use of the
careers portal will be subject to the third party’s privacy practices
as disclosed on the portal, and not to this policy.
Business Transactions.
We may disclose your information in connection with a corporate
transition such as a merger, acquisition, bankruptcy, or sale of all or
a portion of our assets, including during the course of any due
diligence process. By providing your personal information, you agree
that we may transfer such information to the other entity in such
a transaction without your further consent.
For Administrative and Legal Reasons.
We reserve the right to use or disclose any information as needed to
satisfy or fulfill our obligations under any law, regulation, or legal
request; to protect the integrity of the Crayola Canada Properties; to
fulfill your requests; to cooperate in a law enforcement investigation,
an investigation on a public safety matter, or an investigation into
claims of intellectual property infringement; to protect and defend the
legal rights and/or property of Crayola Canada and any of our corporate
parents, subsidiaries, affiliates, and shareholders, or the Crayola
Canada Properties, any of its users, or any other party; or, in an
emergency, to protect the health and safety of users or the general
public.
7. Third-Party Advertising and Analytics
Crayola Canada works with third-party business partners, including
online advertising companies, ad agencies, and analytics providers to
serve Crayola ads online and to provide us with information regarding
the use of the Crayola Canada Properties and the effectiveness of our
advertisements. Crayola Canada allows these companies to place tracking
technologies like cookies and web tags on our Crayola Canada Properties,
and they may otherwise collect or have access to Usage Information and
other information about you. Some of these parties may collect personal
information over time when you visit the Crayola Canada Properties or
other online websites and services. We may share information, typically
information that has been aggregated or de-identified, Usage
Information, and location information with third party advertising
companies, analytics providers, and other third parties, including for
the purpose of serving you more relevant ads on and off the Crayola
Canada Properties.
We may use a variety of companies to serve our
advertisements. Some of these companies are members of the Digital
Advertising Alliance of Canada (DAAC), which provides an opt-out
mechanism for participating companies located at: https://youradchoices.ca/ You may be able to opt-out from interest-based advertising on your mobile device through your mobile device settings.
Mobile
devices may contain settings that allow you to disable tracking
advertising and/or analytics. In addition, the digital advertising
industry has provided the ability for mobile users to register their
intent not to receive targeted advertising. See https://youradchoices.ca/en/tools for more information.
We
use Google Analytics, which uses cookies and similar technologies to
collect and analyze information about the use of the Crayola Canada
Properties and report on activities and trends. This service may also
collect information about the use of other websites, apps, and online
services. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Please
note that opting out through these mechanisms does not opt you out of
being served advertising, and that you will continue to receive generic
ads while online.
8. Your Choices about the Information We Collect
We may provide you with the option to update your information or to
opt out of marketing communications through the profile and/or
preferences section of your account. In addition, you may opt-out of
marketing communications as set forth below.
Email.
You may unsubscribe from marketing emails we send you through the
opt-out mechanism included in each such email. Note, however, that we
reserve the right to send you certain communications relating to your
use of our Services, notices of changes to this Privacy Policy or other
terms, or similar administrative and transactional messages.
Text Messages.
If you sign up to receive SMS or MMS messages from Crayola, you may unsubscribe by replying “STOP.”
Push Notifications
.
We may send promotional and non-promotional push notifications or
alerts to your mobile device, and may in some cases do so based on your
device’s location or physical proximity to a beacon. You can elect to
stop receiving those messages by changing the notification settings on
your mobile device.
9. Your Rights and Access
Accuracy.
Crayola Canada, to the best of its ability, will
strive to collect and maintain the most accurate personal information
available.
Right to Access.
You have the right to access
personal information that Crayola Canada processes about you. You can
request from us information about:
- the personal information we hold about you;
- the categories of personal information concerned;
- the purposes of the processing;
- details to whom your personal information has been/will be disclosed;
- how long we retain your personal information;
- if we did not collect the information directly from you, information about the source; and
- how to lodge a complaint with the correct supervisory authority.
Right to Request the Update and Correction of Inaccuracies
.
You have the right to request the update and correction of inaccuracies
in your personal information in our custody and control, subject to
certain exceptions prescribed by law. You may request the updating and
correction of inaccuracies in your personal information we have in our
custody or control by emailing us at the contact information set out in
Section 15 below. We may request certain
personal information for the purposes of verifying the identity of the
individual seeking access to their personal information records.
Right to Request Deletion.You have the right to request that we delete your personal information in accordance with applicable laws.
10. Security and Breach
Crayola Canada takes commercially reasonable steps designed to secure
your personal information; however, no data transmission over the
Internet, wireless transmission, or electronic storage of information
can be guaranteed to be 100% secure.
Crayola Canada cannot ensure or warrant the security of any information
we collect. You use the Crayola Canada Properties and provide us your
information at your own risk. Mail, voice communications, faxes, and
data transmissions over the Internet are all susceptible to possible
loss, misrouting, interception, and misuse of the information being
communicated or transmitted. You can prevent unauthorized access to your
account and personal information by selecting and securing your access
password properly and limiting access to your computer, device, and
browser. You should always log out after accessing your account.
Crayola
Canada will comply with all applicable laws, and in so complying
provide Crayola Canada users with reasonable assistance, with respect to
any unauthorized use, access, or disclosure of personal information.
11. Retention
Crayola Canada only retains personal information for as long as it is
necessary for the purposes for which it was collected. When personal
information is no longer required for these purposes, it is securely
destroyed or deleted. For further details on our data retention periods,
please contact us. Where you have consented for us to use your details
for direct marketing, we will keep this data until you notify us or
otherwise withdraw your consent.
12. Third-Party Content and Links
The Crayola Canada Properties may contain content that is served by
someone else or links to third-party content or websites. Crayola Canada
does not control this content or these sites. The third-party operators
and content providers use their own cookies or other tracking
technologies, and they may independently collect information from or
about you. Crayola Canada is not responsible for the privacy practices
employed by any third party.
13. Consent to Transfer
As set forth in Section 7 above, we may
share your personal information with Crayola, LLC, which is based in the
United States. In addition, some Crayola Canada Properties (or portions
thereof) may be hosted by servers located in the United States. By
using the Crayola Canada Properties or providing us with any
information, you fully understand and unambiguously consent to this
transfer to, and processing, usage, sharing and storage of your
information in the United States and in other jurisdictions, for which
the privacy laws may not be as comprehensive as those in the country
where you reside and/or are a citizen. As a result, this information
may be subject to access requests from governments, courts, or law
enforcement in the United States and other countries according to the
laws in those jurisdictions. Your information will also be disclosed to
third parties as described in the “How We Share Your Information” section above.
14. Access, Questions, and Concerns
If you have any questions or comments about this Policy, if you wish to
access, update, and/or correct inaccuracies in your personal
information, or if you otherwise have a question or complaint about the
manner in which we or our service providers treat your personal
information, you may contact us at ecom_canada@crayola.com