Privacy Policy

This Privacy Policy (together with the Terms and Conditions, Conditions of Sale, Cookie Policy and any other documents we refer to in this policy or those Terms) explains how we, Imperial Tobacco Company Limited, may collect, use and disclose your personal information when visiting https://www.glo.ca(‘Website’).
We are committed to protecting and respecting your privacy.

Please refer to our Cookie Policy if you would like detailed information on the types of cookies we use on the Website, the purposes for which we use each cookie, how you can disable and enable the use of certain cookies and the consequences of doing so.

If you have any queries or concerns regarding this Privacy Policy, please contact us at support@glo.ca.

• What information do we collect about you
• Verifying your age
• What do we do with information we collect about you
• Safeguards
• Website Information
• Your rights
• Changes to this Policy
• How to contact us

What information do we collect about you:

We collect and process the following information about you (‘Personal Information’):

• information that you submit online via the Website; 
• any correspondence you send to us; 
• details of your visits to the Website and the resources that you access (which may include, amongst other things, traffic data and communication data, information about the device and browser you use, your network connection and your IP address); and 
• details of transactions you carry out or orders you place through the Website and information that you submit online via the Website while placing your orders (which includes your name, email, shipping and billing address, payment details and phone number).

We also automatically collect information about how visitors use our Website by using cookies and similar technology, as outlined below. To learn more about how we use cookies please see our Cookie Policy.

Verifying your age

As this Website relates to tobacco and tobacco products, users of the Website must be adults who have reached the legal age to purchase tobacco products in their jurisdiction of residence (i.e. 18 or 19 years of age, depending on the province). Before you can purchase products from the Website, create a GLO account or subscribe to receive GLO news and information, we must verify your age.

We use a third party to verify your age by confirming that the date of birth you provide to us matches the date of birth on your credit file (but we do not obtain any credit-related information from you).

Any verification check with a consumer reporting agency will be registered as a ‘soft inquiry’ on your credit report. A soft inquiry means that the search was not made for lending purposes and it is only included on your credit report so that you know the search was made. It does not affect your credit rating or score.

What we do with information we collect about you

We use your Personal Information in the following ways:

• to carry out our obligations arising from any contracts with you and for billing and delivery purposes;
• to ensure that the Website’s content is presented as effectively as possible for you; 
• for our internal purposes, such as quality control, Website performance, system administration and to evaluate use of the Website, so that we can provide you with enhanced services; 
• to notify you about changes to our services; 
• to provide you with information, products or services that you request from us, or which we feel may interest you; 
• to verify your age (see the section above for further details); and
• to enable you to participate in the features of the Website, when you choose to do so.

Marketing

If you are an existing customer or you have made a sales inquiry, we may contact you by email / telephone / mail with GLO news and information about products and services that are similar to those we previously provided to you, unless you have indicated that you do not want to hear from us.

You can manage your communication preferences on the Subscription Preference page at Manage Account, on the top navigation. You may ask us at any time not to use your information for marketing purposes or unsubscribe from our communications by contacting us at support@glo.ca.

Sharing your Personal Information

With whom do we share your information? We may share your Personal Information:

• with our agents, mandataries, consultants, data processors and other service providers (including affiliates) if the personal information is necessary to allow these entities to provide services on our behalf. For example, we may use service providers to send email or other communications, host our website, conduct surveys, verify your age and manage and analyze data and our advertising effectiveness. In such cases, your Personal Information will be used to provide the specific services we request and will be kept confidential. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers maintain or process personal information in Canada, the US, EU and other jurisdictions. For additional information on the manner in which our service providers treat your personal information, contact us as set out below;
• with your consent, we may disclose your email address to selected third parties (as described above under the heading of ‘Marketing’) for the purposes we specify when requesting your consent;
• as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of glo.ca or as part of a corporate reorganization or stock sale or other change in corporate control; or 
• along with our Canadian, US and other affiliates and service providers, as required or permitted by applicable law, such as in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), or to another organization in the case of a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

If you pay for a product over this Website, we use a service provider to process your payment. Our service provider operates secure servers to process your payment. They encrypt your payment card information and authorize payment directly. This means that your payment card details are never revealed to us.

Imperial Tobacco Company Limited and its affiliate, Imperial Tobacco Canada Limited, use a centralized system to administer their sites. You can log in to this glo website by using your existing credentials with our brands or with Imperial Tobacco Canada Limited’s platforms. If you choose to use your existing glo credentials on a site that is operated by Imperial Tobacco Canada Limited, we will disclose your personal information in a confidential manner to Imperial Tobacco Canada Limited for the purposes of enabling you to access their website in a seamless manner.

Safeguards

We have put in place a series of security safeguards designed to protect your Personal Information against loss and theft, as well as unauthorized access, disclosure, copying, use and modification, regardless of the format in which the information is held.

These security safeguards include physical measures, administrative measures and technological measures that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored.

We also take the necessary measures to ensure that all our managers and employees are informed on the contents of this Policy and requirements under applicable privacy legislation, and understand that they are required to conform to it at all times. Access to personal information strictly limited on a need-to-know basis to the persons for whom such information is necessary for the performance of their functions and duties. Unauthorized access to or disclosure of your personal information by one of our employees is strictly prohibited and will result in appropriate disciplinary measures.

We will keep your Personal Information for the time required to fulfill the identified purposes, our legitimate business purposes and to conform to legislative requirements.

If you have a username, password or other login details that enable you to access certain parts of the Website, you must not allow any other person to use them and must treat them as confidential. If you believe or suspect that someone else knows your login details you must contact us at support@glo.ca as soon as possible. Please also see our Conditions of Sale.

Website Information

We and/or our service providers collect the IP (Internet protocol) addresses of all visitors to our website and other related information such as page requests, browser type, operating system and average time spent on our website. We use this information for statistical purposes and to help us understand our website activity, and to monitor and improve our website. We also use a technology called “cookies”. A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our website where you are prompted to log in or that are customizable. If you have registered with our website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to deliver products and personalized content or services, and (3) will provide us and our service providers with information that we use to personalize our website in accordance with your preferences and to better understand our website activity. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all features of our website. Please see our Cookie Policy for more details.

We and our service providers (such as Google Analytics) also use cookies to help us understand our website activity, to improve our website and provide better customer service. For more information about Google Analytics, see www.google.com/policies/privacy/partners/.

Our website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our website. These tracer tags are used to help us optimize and tailor our website for you and other future visitors to our website.

Our website may contain links to other sites that we do not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

User Password Across our Digital Platforms

You may be able to use your email address and password across all of Imperial Tobacco’s digital platforms.

Where do we transfer your information?

We and our service providers may transfer your Personal Information to, or store it in, countries located outside Canada including the European Economic Area (‘EEA’) and the United States. For more information about how we or our service providers process your Personal Information, contact as us outlined below.

Your rights

We recognize that it is important to keep personal information accurate, complete and up-to-date and we take reasonable steps to ensure the accuracy and completeness of the Personal Information we use and discloses. However, you are responsible for informing us at the contact information set out below of any significant change in your Personal Information which may occur during the course of our relationship.

You have the right to request access to your Personal Information which is in our custody or control, subject to limited exceptions prescribed by law. You can also request that information which is inaccurate or incomplete be rectified.

We will respond to every request for access and rectification, in accordance with applicable laws. In the event that we cannot provide access to or rectify your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions, and we will provide you with any recourse available. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Changes

We may make changes to this Privacy Policy from time-to-time. We will post updates on the Website, and where appropriate, notify you about material by sending you an email with the modified terms or by posting a copy of them on the Website.

How to contact us

If you wish to contact us with any queries or concerns, please see our Contact Us page or email us at support@glo.ca or write to our Privacy Officer at:

Imperial Tobacco Canada Limited
3711, St-Antoine Street West
Montréal (Québec) H4C 3P6
1-800-932-9326

Last Posted March 1st 2018