Website Privacy Policy

1. Privacy
Great White North Franchisee Association (“us,” “we,” “our”, or “GWNFA”) respects the privacy rights of visitors and users of our information and membership services (collectively, “Services”) provided through our website and any application software for any platform (iPhone, Windows, Blackberry, Android etc.) that you may download (collectively, the “Website”). We created this Website privacy policy (“Privacy Policy”) to give you confidence as you visit and use the Website, and to demonstrate our commitment to the protection of any personal information we hold.

GWNFA is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this Privacy Policy and trained our employees about our policies and practices.

This Privacy Policy is only applicable to the Website. Our Website contains links to other sites. Those sites are not governed by this Privacy Policy. Your use of the Website is governed by this Privacy Policy and the Terms of Use.

2. Website Data Collected
We automatically track and collect the following categories of information when you visit our Website: (1) IP (which stands for Internet Protocol) addresses; (2) domain servers; (3) types of computers accessing the Website; (4) types of web browsers used to access the Website; (5) referring source which may have sent you to the Website; and (6) other information associated with the interaction between your browser and the Website (collectively, “Website Data”).

3. Personal Information Collected
We provide our Services through our Website. In order for you to access certain areas of the Website, we require you to provide us with certain personal information that identifies you, or from which your identity could be deduced (“Personal Information”). Personal Information includes: (1) Contact Data (such as your e-mail address, username, and GWNFA password); (2) Demographic Data (such as your gender and your postal code / zip code); and (3) Professional Data (such as the name of your business, store information, etc.). If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information. If we did not collect and use your Personal Information we could not provide you with our Services.

You may choose not to provide us with any Personal Information. In such an event, you can still access and use some of the Website; however you will not be able to access and use those portions of the Website that require your Personal Information.

If you access any Services requiring a user name and password, you are solely responsible for keeping such items strictly confidential.

4. Anonymous Member Data and Information
Certain of our members have indicated a wish to remain anonymous, meaning that their information, including Personal Information, will not be disclosed to us. Instead, the collection, use and storage of anonymous members’ information is the responsibility of our legal counsel, Himelfarb Proszanski Barristers and Solicitors. As such, references in this Privacy Policy to “us”, “we”, “our” or “GWNFA” include Himelfarb Proszanski Barristers and Solicitors in cases where a member is anonymous.

5. Credit and Debit Card Information
Payment details, including name, surname, billing address, and debit and credit card information, submitted to GWNFA (“Payment Details”) will be processed by our online payment provider Stripe, Inc. who will process, store, and transfer such information outside of Canada in accordance with its own privacy policy (see: https://stripe.com/ca/privacy). Please note that GWNFA does not accept any responsibility or liability for Stripe, Inc.’s privacy policy. By submitting your Payment Details you consent to such transfer, storage, and processing by Stripe, Inc. GWNFA and Stripe, Inc. will take all steps reasonably necessary to ensure that your data is treated securely.

Certain Payment Details will be retained by GWNFA’s legal counsel, Himelfarb Proszanski Barristers and Solicitors, for administrative and legal purposes and will be treated in accordance with this Privacy Policy. These Payment Details will be stored on secure Himelfarb Proszanski Barristers and Solicitors servers.

6. Website Tools
We also collect other information, which may include Personal Information that you voluntarily provide to us when you use some of the Website’s interactive tools and services (“Website Tools”), such as searching and browsing. We also collect information you provide voluntarily through the Website and through responses to questionnaires and surveys. Some of the free Website Tools on our site ask you for Personal Information.

7. Cookies
“Cookies” are computer files that are placed on your computer by a website. In these files various pieces of information can be stored, from user identification and preferences to activities conducted while browsing the Website. You may block cookies or delete cookies from your computer if you wish but must do so at your own cost and responsibility. If you do block or disable cookies, you may not have access to the entire set of features of our Website.

Generally, we use “cookies” to customize your experience on our Website and to store your password so you do not have to re-enter it each time you visit the Website.

We do not link the information stored in these cookies directly to any of your Personal Information you submit while on the Website.

8. Website Analytics
We may use third party website analytics services with our Website. The information tracked by these services includes, but is not limited to, pages visited, users’ browsers and operating systems, users’ approximate geographic location, users’ internet service providers, length of time spent on pages, and how users reached our Website. We use this data to generate statistics which help us to optimize our Website and improve the user experience. Analytics data is stored on third party servers, not on GWNFA’s servers. These services tracks individual users based on anonymous IP addresses. Please note that if you have an account with GWNFA, we may be able to link your personal information with the browsing information tracked by the third party analytics service provider.

9. Storage of Information
We store all Website Data and review postings indefinitely, even after they are deleted, and may retain such information elsewhere. We store all Personal Information until you request that we amend or delete it, in which case we may still end up retaining some of that information for the reasons described in Section 14 below.

10. Personal Information Protection and Electronic Documents Act
From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association Model Code for the Protection of Personal Information that it incorporates. PIPEDA gives you rights concerning the privacy of your personal information.

11. GWNFA’s Use of Your Information
We may use your Contact Data to send you information about GWNFA Services, to contact you when required, including to inform you of Services, and in conjunction with your use of certain Website Tools.

12. Information Sharing
We share certain categories of information we collect from you in the ways described in this Privacy Policy. We may share Personal Information with our business partners who assist us by performing core services related to our operation of the Website and/or by making certain Website Tools available to our users. Those business partners shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Personal Information to carry out their specific business obligations to GWNFA and to provide your requested services. GWNFA does not provide your Personal Information to any third parties for their promotional purposes.

13. Confidentiality
Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Personal Information or any other information we collect about you is necessary to: (1) comply with a court order or other legal process; (2) protect the rights, property, or safety of GWNFA or another party; (3) enforce our Terms of Use; or (4) respond to claims that any posting or other content violates the rights of third-parties.

14. Controlling and Correcting Your Personal Information
Since we use your Personal Information to provide Services to you, it is important that your Personal Information be accurate and up-to-date. If any of your Personal Information changes, please advise us so that we can make any necessary changes (you must either write to us directly at the address or email set out in Section 22 below or, if you are a registered user of our Website, you can modify some of your Personal Information you have included in your profile).

Upon your written request, we will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may not be possible to remove your account without some residual information being retained by us. Registered users who wish to close their account should contact info@gwfna.ca or, if anonymous members, jleech@himprolaw.com.

If we hold Personal Information about you and you can establish that it is not accurate, complete, and up-to-date, we will take reasonable steps to correct it.

15. Access to Your Personal Information
You may ask for access to any Personal Information we hold about you. Summary information is available on request. More detailed requests that require archive or other retrieval costs may be subject to our normal professional and disbursement fees.

Your rights to access your Personal Information are not absolute. We may deny access when:

• Denial of access is required or authorized by law;
• Information relates to existing or anticipated legal proceedings against you;
• When granting you access would have an unreasonable impact on other people’s privacy;
• When to do so would prejudice negotiations with you;
• To protect our rights and property; and
• Where the request is frivolous or vexatious.

If we deny your request for access to, or refuse a request to correct your Personal Information, we shall explain why.

16. Public Information
Any information that you may reveal in a review posting or other online discussion or forum is intentionally open to the public and is not in any way private. You should carefully consider before disclosing any personally identifiable information in any public forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

17. Security
The security of your Personal Information is important to us. We take reasonable precautions to ensure that your Personal Information is kept safe from loss, unauthorized access, modification, or disclosure. Among the steps taken to protect your Personal Information are:

• Premises security;
• Vulnerability management;
• Secure coding practices;
• Restricted file access to personal information;
• Network security (any and all restrictions in place with respect to source IP, destination ports/protocols, segmentation, VPNs, etc);
• Deploying technological safeguards like encryption and security software and firewalls to prevent hacking or unauthorized computer access; and
• Internal password and security policies, including authentication and authorization.

“Phishing” is a fraudulent practice designed to steal your Personal Information. If you receive an e-mail that looks like it is from GWNFA asking you for your Personal Information, do not respond. We will never request your password, user name, credit card information, or other Personal Information through e-mail.

A website cannot be completely absolutely protected against intentional or malicious intrusion attempts. Further, we do not control the devices or computers or the internet over which you may choose to send Personal Information and cannot, therefore, prevent such interceptions of compromises to your Personal Information while in transit to us. If we learn that your Personal Information has been disclosed in a manner that is not in accordance with this Privacy Policy, we will use reasonable efforts to advise you of the disclosure as soon as reasonably possible.

18. Lost or Stolen Information
You must promptly notify us in writing at the address or email set out in Section 22 below if your Contact Data is lost, stolen, or used without your permission. In such an event, we will remove that Contact Data from your account and update our records accordingly.

19. Links to Other Websites
Website contains links to third party websites to which GWNFA has no affiliation. We do not share your personal information with those websites and we are not responsible for their privacy practices. Some websites may be similar to our Website. Please be cautious that you may be on a different site and that this Privacy Policy only covers our Website. Should you decide to visit one of these third party websites, we recommend that you read its privacy policy.

20. Updates and Changes to Privacy Policy
Since we regularly review all of our policies and procedures, we may change our Privacy Policy from time to time. All changes will be posted on our website. In all cases, use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

21. E-mail
You should be aware that e-mail is not an entirely secure medium. You should be aware of this when using e-mail to send or receive personal or confidential information.

22. Limitation of Liability
We make no guarantee as to security, integrity, or confidentiality of any information transmitted to or from our Website, or stored within our Website. Beyond our reasonable care to safeguard your information while in transit, GWNFA does not guarantee the absolute security of electronic communications or transmissions since any transmission made over the internet by anyone individual runs the risk of interception.

You assume the sole risk of transmitting your Personal Information as it relates to the use of our Website, and for any data corruptions, intentional interceptions, intrusions, or unauthorized access to Personal Information, or of any delays, interruptions to or failures preventing the use our Website. In no event shall we be liable for any direct, indirect, special, consequential, or monetary damages, including fees and penalties in connection with your use of the Services provided by our Website or connectivity to or from this site to any other site.

23. Contacts
If you have any questions concerning our Privacy Policy, wish to write to us, or wish to access your personal information, please write to or call our Privacy Contact at:

Great White North Franchisee Association
2133 Royal Windsor Drive, Suite 23
Mississauga, Ontario
L5J1K5

E-mail: info@gwfna.ca

If you are an anonymous member, you may also contact our legal counsel at:

Himelfarb Proszanski Barrister & Solicitors
480 University Avenue, Suite 1401
Toronto, Ontario
M5G 1V2

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street
Ottawa, Ontario K1A 1H3 1
Phone: 1.800.282.1376.

BY USING THIS WEBSITE, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY IN ITS ENTIRETY WITHOUT ANY MODIFICATION.