We, Giampaolo Investments Limited, (“GIL”) and our affiliates and subsidiaries respect your individual privacy. This privacy policy (the “Privacy Policy”) embodies our commitment to its protection through adherence to fair electronic information practices. This Privacy Policy puts you in control of how your personal information is processed. You have our promise that we will not electronically process your personal information in any way that is incompatible with this Privacy Policy.

1. Collection and Use of Personal Information

With your consent, we use your personal information for purposes of monitoring and improving our internal operations, as well as to ensure we (i) administer your Account in accordance with your agreements with us, (ii) properly perform the services you have requested, (iii) comply with applicable provincial and federal legal requirements, (iv) identify your preferences as a customer, (v) inform you about upcoming events, promotions and new and improved services, (vi) protect you and GIL against error and fraud, and (vii) comply with our internal risk management and related policies. We also use the personal information we collect to monitor and improve our internal operations, as well as to improve the experience of users in our network of web sites. For example, we may correlate web site traffic information with data about individual users. This data helps us to determine how much our customers use parts of this web site (the “Site”), allowing us to enhance it to fit the needs of as many of our customers as possible. GIL owns and operates the Site. This Privacy Policy applies to information we collect when you use the Site and its services (collectively, the “Services”) with respect to the Site.

GIL does not collect personal information about you except when you provide it to GIL on a voluntary basis, and does not collect, use or disclose Your personal information without first obtaining your consent.

During your use of the Site, you may be asked to voluntarily provide personal information (including without limitation your name, email address, postal address, telephone number, fax number, profile data, postal code, age, and gender to GIL. If you choose not to provide certain personal information, you may not be able to use certain features of the Site, and/or you may not be able to receive products and services from GIL. Such personal information is collected from you at the Site when you complete a survey, request to be notified or request information, products or services. For the purposes of verification of your identity when you create an account, you specifically acknowledge that GIL may provide your personal information to a third-party provider for the verification of your age, residency and other identifiable information for the purposes of providing you an Account with GIL.

Your contact information is used when GIL needs to contact you directly. It is also used to identify what future products or services you may require. GIL will not sell your personal information or otherwise share it with third parties without your permission. We use the information we collect to direct important notices and information affecting your Account or services on the Site as well as to provide general information that may be of interest to you which may include newsletters, surveys, contest announcements, and information about our service or product offerings or the offerings of our business affiliates.

We collect the personal information that you provide to us when you contact us to request support or otherwise communicate with us in connection with the Services. If you choose to participate in a GIL survey or contest we will collect the personal information you provide for the purposes of administrating the contest or survey.

You may opt-out of receiving information from us simply by notifying us by writing to the address below or by e-mailing us at priavcy@gg-inc.ca or in accordance with the opt-out instructions contained in any information message you receive from us.

When you access or use the Services, we automatically collect information about you, including:

a)    Log Information: We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
b)    Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
c)    Location Information: We may collect information about the location of your device when running Site applications or otherwise consent to the collection of this information.
d)    Machine Usage Information: We collect information about your use of our machines through Services.

We use this information for the purposes of providing, maintaining, analyzing and improving our Services, detecting, investigation and preventing illegal activities and to protect the rights of GIL and others.

2. Obtaining Consent

GIL will collect, use and disclose your personal information only with your consent except where otherwise required by law. You may decline to provide us with your personal information; however, this choice may make it impossible for us to provide you with some or all of our products or services. By applying to use, or using the Site, including by applying to use the products and advertised and offered through the Site, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you may not use the Site.

Some of our products and services are governed by federal and provincial regulations that require GIL to collect and maintain specific personal information. As well, in order to fulfill our service obligations to you, it is necessary for GIL to have your consent to send you notices and other important information affecting your Account or services. In order to continue providing you with products and services, it is necessary for GIL to have your consent to provide your personal information to (i) a company or individual employed by GIL to perform functions on its behalf, (ii) a company or person for the development, enhancement, marketing or provision of GIL’s products or services, and/or (iii) an agent or third-party retained by GIL in connection with GIL’s administration or the provision of GIL’s products or services.

If GIL provides your personal information to any third-party, we will require that third-party organizations to protect and maintain your personal information in compliance with the terms and conditions of this Privacy Policy.

3. Updating your Information and/or changes to your preferences including Withdrawing your Consent.

We offer you several ways to update your contact information and/or to change your preferences. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw your consent, simply (i) unsubscribe to any of our online communications by following the unsubscribe instructions in the body of any email message; (ii) contact us by writing to the address below to the attention of the Privacy Officer or (iii) by emailing us at privacy@gg-inc.ca and advising which of your personal information you no longer wish us to collect, use and/or disclose. We will the inform you of the implications of withdrawing consent to collect, use and/or disclose that personal information, including without limitation the fact that once such consent is withdrawn you may not be able to use certain features of the Site, and/or may not be able to receive products and services from GIL. Should you nonetheless still desire that consent be withdrawn, GIL will accede to your request.

We will take commercially reasonable steps to implement your opt-out requests promptly but you may still receive promotional information from us by mail for up to ninety (90) days due to printing and mailing schedules, and up to ten (10) business days for email. You may also continue to receive information from those third parties to whom your information was previously disclosed.

4. Maintenance and Disposal of Personal Information.

The information you have provided us is maintained in our management information system and is updated as new information is added. Records may remain on file even after you have terminated our Account. Subject to applicable law, we may also keep records to facilitate collection and to evaluate credit worthiness.

We destroy customer information that is no longer necessary for the purpose for which it is collected unless there is a legitimate request or order to inspect the information still outstanding or the information remains in routine records that are periodically discarded under our document retention policies.

5. Disclosure of Personal Information.

Your personal information will not be used or disclosed without your consent, except where required or permitted by law. We will only use and disclose your personal information to fulfill the purposes for which it was collected or as otherwise identified in this Privacy Policy. Other uses of your personal information will only be undertaken after we have obtained your additional consent, or as may be required by law. We will only keep Your personal information for as long as needed for the stated purposes.

Your personal information will not be sold to any organization for any purpose. We will not disclose your personal information to any third-party without your consent, except that we reserve the right to disclose your personal information: (a) to any of our affiliates, subsidiaries, third-party service providers or advisers that we deem appropriate; (b) if such disclosure is made pursuant to a legal proceeding or as required by law; (c) to another business entity should we plan to merge with, or be acquired by that business entity; or (d) organizations involved in a merger, transfer or sale of our assets or business.

In the event that we disclose your personal information as set out above, we will require third-party organizations who have access to your personal information to protect and maintain your personal information in compliance with the terms and conditions of this Privacy Policy.

6. Non-Personal Information and Use of Cookies.

Like many other web sites you may visit, the Site automatically collects certain non-personal information regarding you, such as the date and time you access the Site, the Internet address of the web site from which you linked to the Site, the operating system you are using, and the Site pages read and images viewed. This non-personal information is used for system administration purposes and to improve the Site. Non-personal information may be disclosed to other persons and permanently archived for future use.

The Site also uses “cookies”, a technology that installs a small data file onto your browser from a web server which is then stored on your computer’s hard drive, which thereafter permits the Site to recognize future visits from that computer. Cookies do not damage your system or impair its functioning in any way. GIL uses cookies to tailor and enhance your experience at the Site, to show you content that you might be interested in, and to display the content according to your preferences. Cookies do not contain any personal identifying information and only contain information such as a user ID that a web site uses to track the pages you have visited. The only personal information a cookie can contain is information you supply yourself. We use cookies to track user traffic patterns when you make any requests for GIL services. When you make your request, we may use a cookie to store a unique, random user ID. We use this ID to identify you anonymously in our database and to track the pages you visit on the Site. You can reset your browser to refuse all cookies or to allow your browser to show you when a cookie is sent. Please note that if you chose to remove or reject cookies, this could affect the availability and functionality of the Site and/or Services.

7. Third-Party Links and Websites

The Site contains links to other web sites. You understand and agree that your use of such third-party web sites will be governed by the privacy policies of those web sites and not by this Privacy Policy. The Site is not responsible or liable for the use of your personal information that may be collected by a third-party web site that has a link on the Site. GIL is not responsible nor liable for the privacy practices or the content of any such third-party web sites. GIL does not control, monitor or endorse the information gathering practices or privacy policies of any such third-party websites. Whenever applicable, you should seek to read the privacy policy of any third-party web site that has a link on the Site.

8. Public Forums

Please be aware that any information (personal or otherwise) that is disclosed online in a message board or chat room makes that information public information. You should exercise caution when deciding to disclose your personal information online. GIL is not responsible for personally identifiable information posted on such message boards or chat rooms.

9. Security

GIL has adopted and implemented and will maintain reasonable and technologically feasible procedures for maintaining the security, accuracy and integrity of all personal information that is collected by the Site in order to attempt to protect against the loss, misuse and alteration of the personal information under our control.

All data is kept on secure database servers which are all behind a firewall with very restrictive access. All data entry is done via a secure interface that provides no export facility. Please be advised, however, that the Internet and other various networking communication mediums are not secure, unless explicitly specified as such, and may be subject to interception or loss which is beyond the control of GIL. Also be advised that the security, integrity and privacy of any and all information and data exchanged between you and GIL through the Site cannot be guaranteed. You should consider any information provided to or collected by the Site as non-confidential, and consequently the Site assumes no liability or responsibility if any of your personal information is intercepted and/or used by an unintended recipient.

GIL will not monitor, edit or deliberately disclose the contents of your private communications or files, except in circumstances where we inadvertently obtain information that appears to pertain to the commission of a crime or where we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person exists. In such cases, GIL may voluntarily disclose the record or the contents of your communications or other information about you to law enforcement agencies and governmental entities without providing you advance notice. Upon receipt of an applicable search warrant or subpoena, GIL may be required to disclose to the government or law enforcement agencies, without advance notice to you, the content of your communications and other records relating to your electronic communications, as well as the following records: Your name and address; records of your online communications (including session times and duration); how long you have subscribed to our service(s) (including start date) and the type(s) of service(s) utilized; your telephone number, subscriber account identifying number(s) and/or information, including any Internet or network address(es) assigned to you by our network.

10. Children’s Guidelines

The Site is not intended for children. GIL will not knowingly collect information from children under the age of 13.

11. Changes to this Policy

GIL shall periodically review the appropriateness of this Privacy Policy and shall make, at its sole discretion, such changes or modifications as may be deemed necessary. Such changes and modifications shall be made without any prior notice or liability to you or any other person. GIL’s collection, use and disclosure of your personal information will be governed by the version of this Privacy Policy in effect at that time. New versions of the Privacy Policy will be posted on the Site and are available upon request from GIL. Your continued dealings with GIL or your use of the Site subsequent to any changes or modifications to this Privacy Policy will signify your consent to the collection, use and disclosure of your personal information in accordance with the changed Privacy Policy. Accordingly, when you use the Site You should check the date of this Privacy Policy and review any changes since the last version you reviewed. You should periodically review this Privacy Policy to ensure that you are familiar with the most current version.

12. Opt-Out Options and Access to Your Information.

The Site provides you the opportunity to opt-out of receiving communications from us at the point where we request registration information about the visitor.

If You desire access to your own personal information held by GIL, please contact us by writing to address below, attention Privacy Officer or by e-mailing us at privacy@gg-inc.ca.

At the time of your request for access to your personal information, we will need specific information to verify your identity before we can provide you with the personal information requested. In some instances, we will not be able to provide you with the personal information you request, for instance where that information (i) contains references to other persons, (ii) has been destroyed due to legal requirements or because the information has served its purposes, or (iii) is subject to legal protections that prevent disclosure (e.g. information this is subject to solicitor-client or litigation privilege). If we are unable to provide you with access to your personal information, we will explain why and advise you as to any recourse available to you.

We are committed to maintaining the accuracy of your personal information, and we encourage you to notify us of inaccuracies or corrections. Timely notification of a change of address or telephone number helps us in providing You with the best possible service. You may change your personal information in our records at any time and as often as necessary. If you request removal or deletion of your personal information, you acknowledge that residual information may continue to reside in GIL’s records and back-up systems.

13. Contact Us

If You have any questions, concerns or complaints regarding your personal information or this Privacy Policy, you may contact us at the address listed below. We will inform you of our complaint procedures and assist you in resolving the situation. If a complaint is found to be justified, appropriate steps will be taken including, if necessary, revisions to our practices and procedures.

Giampaolo Investments Limited
301-1 Kenview Blvd.
Brampton, ON L6T 5E6
Attention: Privacy Officer

Or by email Privacy@gg-inc.ca

14. Intellectual Property Notice

Copy Last Updated: April 1, 2019