updated 20 May 2018

Anodyne Electronics Manufacturing Corp. (AEM) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are 
 
Purpose of this privacy notice 

This privacy notice aims to give you information on how Anodyne Electronics Manufacturing Corp. (AEM) collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or submit a form to engage us in repair or refurbishment services. 

This website is not intended for children, and we do not knowingly collect data relating to children. 

It is vital that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

Controller 

Anodyne Electronics Manufacturing Corp. (AEM) is the controller responsible for your personal data (collectively referred to as “we,” “us” or “our” in this privacy notice). 

We have appointed a data privacy manager who is responsible for overseeing questions concerning this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

Contact details 
Our full details are: 
Full name of legal entity: Anodyne Electronic Manufacturing Corp. (AEM) 
Name or of data privacy manager: Brad Grainge 
Email address: brad.grainge @aem-corp.com 
Changes to the privacy notice and your duty to inform us of changes 
This version was last updated on 20 May 2018, and historical versions can be obtained by contacting us. 
 
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 
 
2. The data we collect about you 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: 

• Identity Data includes first name, maiden name, last name, username or similar identifier, and title. • Contact Data includes a billing address, delivery address, email address, and telephone numbers. • Financial Data includes bank account and payment card details. • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. • Usage Data includes information about how you use our website, products and services. • Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences. 

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used under this privacy notice. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 
 
3. How is your personal data collected? 

We use different methods to collect data from and about you, including: 

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

• apply for our services;

• request marketing to be sent to you;

• complete our questionnaires;

• make a payment through our website; or

• give us feedback. 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
 
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 

Technical Data from the following parties: 

• analytics providers such as Google based outside of Canada;

• advertising networks such as Google based outside of Canada; and

• search information providers such as Google based outside of Canada. 

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal based outside of Canada. 

Identity and Contact Data from data brokers or aggregators such as Google based outside of Canada. 
 
4. How we use your personal data 
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending thirdparty direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. 
 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact Performance of a contract with you 
 
To process and deliver your order including:

 
(a) Identity
 
(a) Performance of a contract with you
a) Manage payments, fees and charges  (b) Contact  (b) Necessary for our legitimate interests (to recover debts due to us) 
(b) Collect and recover money owed to us  (c) Financial 
(d) Transaction 
(e) Marketing and Communications 
 
To manage our relationship with you which will include: (a) Identity (a) Performance of a contract with you
(a) Notifying you about changes to our terms or privacy policy 

(b) Contact 
 

(c) Profile

(b) Necessary to comply with a legal obligation 

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) 
(b) Asking you to leave a review or take a survey 

(d) Marketing Communications

 
To enable you to partake in a prize draw, competition or complete a survey (a) Identity (b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact 
(c) Technical 
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications 
(f) Technical 
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
b) Usage 
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact 
(c) Technical 
(d) Usage 
(e) Profile 
Necessary for our legitimate interests (to develop our products/services and grow our business) 
     

 
Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you; this is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. 

Opting out 

You can ask third parties or us to stop sending you marketing messages at any time by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. 

Cookies 

You can set your browser to refuse all or some browser cookies or to alert you when websites place or access cookies. If you disable or reject cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy. 

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original intent.If you wish to get an explanation as to how the processing for the new purpose is consistent with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 
 
5. Disclosures of your personal data
 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

External Third Parties as set out in the Glossary. 

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other companies or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We require all third parties to respect the security of your personal data and to treat it under the law. We do not allow our thirdparty service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 
 
6. International transfers 

Some of our external third parties are based outside of Canada, so their processing of your personal data will involve a transfer of data outside of Canada. 

Whenever we transfer your personal data out of Canada, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). For further details, see Officer of the Privacy Commissioner of Canada: Personal information transferred across borders https://www.priv.gc.ca/en/privacy-topics/personal-information-transferred-across-borders/ 

Where we use certain service providers, we may use specific contracts approved by the Privacy Commissioner of Canada which give personal data the same protection it has in Canada.  

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Canada. 
 
7. Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Also, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 
 
8. Data retention 

For how long will you use my personal data? 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

In some circumstances you can ask us to delete your data: see Request erasure below for further information. 

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 
 
9. Your legal rights 

Under certain circumstances, you have rights under data protection laws concerning your personal data. 
If you wish to exercise any of the rights set out below, please contact us. 

You have the right to: 
 
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.  

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.  

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
 
• Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
 
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the information is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
 
• Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to electronic information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
 
• Withdraw consent at any time where we are relying on approval to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you remove your permission, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

No fee usually required. 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

What we may need from you.

 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several claims. In this case, we will notify you and keep you updated. 
 
Glossary 

LAWFUL BASIS
 
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

“Performance of Contract” means processing your data where it is necessary for the production of a contract to which you are a party or to take steps at your request before entering into such a contract. 

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject. 

THIRD PARTIES 

External Third Parties Service providers including Google Analytics acting as processors based in the USA who use data analytics to improve our website, products/services, marketing, customer relationships and experiences. 

Online payment service providers including PayPal acting as processors based in the USA which facilitate payment transactions.