Scope of this Policy
GS Distribution's Accountability
Please see "Contacting Us" below for information on how to contact our Designated Privacy Officer.
What is Personal Information?
We collect and maintain different types of personal information in respect of individuals with whom we interact. GS Distribution may collect personal information that you provide when you:
- purchase, order, return or exchange any of our products and services online, over the telephone or in person;
- request a copy of an invoice;
- request a quote, special order or information about any of our products and services;
- contact our customer service staff;
- apply for employment;
- provide us with comments or suggestions; or
- visit our website or any of our physical locations.
The personal information we collect includes the following:
- contact and identification information, such as name, address, telephone number and e-mail address;
- information concerning the products and services we provide to, or receive from, you, including with respect to the service, maintenance and repair history of such products;
- credit and financial information such as payment methods and preferences, and billing and credit history;
- business relationship information, including information related to your agreements, preferences, advisors and decision-makers; and
- customer relationship information such as customer service requests and feed-back and information requested or provided by or from you.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.
As a general rule, GS Distribution collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). The third parties that we may collect information from include credit reporting agencies (for the purpose of conducting a credit check where you wish to obtain credit from us).
From time to time, we may utilize the services of third parties (including other members of the GS Distribution Group in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
How Do We Use Your Personal Information?
We use the personal information we collect to enable us to manage and develop our business and operations, including for the following purposes:
- to establish, maintain and manage relations with our customers (for example, we will use personal information to establish a customer's identity and location so that we may accurately deliver and bill for products and services);
- to establish, maintain and manage relations with our suppliers;
- to analyse customer requirements for our products and services so that we may work to improve our products and services;
- to communicate with suppliers in order to improve the products and services supplied to us;
- to be able to inform you of products and services that members of the GS Distribution Group, or third parties that we have carefully selected as partners, may wish to offer you, including sending you information promoting the products and services of those members or partners;
- to be able to comply with your requests;
- to verify your identity (for example, name, address, telephone number and birth date, if applicable);
- to verify creditworthiness;
- to protect us against error, fraud, theft and damage to our goods and property;
- to enable us to undertake our environmental, health and safety activities, including incident planning, response and investigation;
- to enable us to comply with applicable legal, audit or regulatory requirements (for example, we may collect personal information to satisfy the obligations imposed on us by various regulatory boards or agencies to follow procedures mandated by such boards or agencies in respect of the provision of our products and services); and
- any other reasonable purpose to which you consent.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When Do We Disclose Your Personal Information?
Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of GS Distribution’s regular reporting activities to other members of the GS Distribution Group including GS Distribution affiliates outside Canada;
- to protect the rights and property of GS Distribution (for example, to collect a debt or to protect ourselves from fraud);
- when we require legal advice from a lawyer;
- in an emergency that threatens an individuals life, health, or personal security;
- when the personal information is available from a public source (for example, the telephone book) or
- with your consent, where such consent is required by law.
If you provide us with your email address, we may send you email messages to keep you informed of our promotions and offers by using your first and last name, postal code and email address. In order for GS Distribution to provide you with these email messages, we may need to pass your name and contact information to our service providers who assist with the delivery of this email service. We may also use third party companies to authenticate and validate your email address.
Our policies prohibit our service providers from using your information for any purpose other than how GS Distribution instructs them. Therefore, if you sign up for our email newsletters or other email communications, you should not receive unsolicited emails from other companies. Please notify us at the address below if you believe this has occurred.
In addition to the information you provide, if you visit our website, we may collect information during your visit using automatic data collection tools such as cookies, web beacons, embedded web links and other commonly used information-gathering tools which collect certain standard information which your web browser sends to our website during your visit. GS Distribution may use this information to analyse customer activity, composition of web traffic and to make improvements to its website.
Your Consent is Important to Us
It is important to us that where we collect, use or disclose your personal information we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you accept our products or services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time.
As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
How Long Do We Retain Your Personal Information?
GS Distribution endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. GS Distribution will also use appropriate security measures when destroying personal information, and instead of destroying or erasing your personal information, may make it anonymous such that it cannot be associated with or tracked back to you.
Access to Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Designated Privacy Officer using the contact information set out below. Any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. We may charge you a minimal fee to access your personal information, however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Designated Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.