Updated and Effective as of Jan 5, 2022
This Policy regarding how personal information entrusted to us is collected, used, disclosed, or retained reflects the principles set forth in Canada’s Personal Information Protection and Electronic Documents Act, SC 2000, c 5.
Table of Contents
- General Audience Sites
- Consent for Personal Information
- Information We Collect
- How We Use Your Information
- How We Share Your Information
- Third-Party Advertising and Analytics
- Your Choices About the Information We Collect
- Your Rights and Access
- Security and Breach
- Third Party Content and Links
- Consent to Transfer
- Access, Questions, and Concerns
2. General Audience Sites
The Crayola Canada Properties are not intended for use by children under the age of 18. We do not knowingly collect personal information from children younger than age 18.
3. Consent for Personal Information
We collect information about you directly through the Crayola Canada Properties, automatically when you visit the Crayola Canada Properties, and sometimes from third parties. Some of the information we collect may be considered “personal information” under applicable laws. Personal information is any information about an identifiable individual. Personal information includes information that relates to personal characteristics (e.g., gender, age, income, home address, or phone number, ethnic background, family status), health (e.g., health history, health conditions, health services received), or activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).
Crayola Canada collects and processes personal information in accordance with this Policy. Crayola Canada collects, uses, and discloses personal information for the purposes described in this Policy, including providing our products, services, promotions, and events to you. We will not sell, share, or rent this information to others, except as set out in this Policy.
By providing Crayola Canada with your personal information, you consent to the collection, use, and disclosure of such information in accordance with this Policy or for the purposes identified to you at the time you provided the personal information. Any secondary use of the personal information will only be processed with your express consent, except as required by law.
You have the opportunity to withdraw your consent, or to opt-out at any time. If you wish to withdraw your consent or to opt-out at any time, including to remove yourself from our email or mailing list, please contact us as set out in Section 15 below.
4. Information We Collect
Information you provide directly to us. When you use the Crayola Canada Properties, we ask you to provide us with certain information. This information will depend on the Crayola Canada Property you interact with, and may include without limitation:
- First and last name
- Email address, phone number and other contact information
- Shipping and billing addresses
- Demographic information, such as your date of birth and gender
- Account information
- Photographs, video messages, handwriting, and other data provided by you as part of a product review, question, or other user submission
- Wish list or other favourites information
- Information provided by you in responses to surveys, quizzes, or in community forums
- Information provided by you as you interact with our customer-support team
- Information provided by you as you provide feedback through the Crayola Canada Properties on our products or services
- Information relating to transactions and products and services purchased, including payment information, and return and exchange information
- Information relating to your application for employment with Crayola Canada
Information collected automatically. We, our service providers, business partners, and/or other third parties may automatically collect and/or store certain information when you visit or interact with the Crayola Canada Properties (“Usage Information”). This Usage Information may be stored and/or accessed from your computer, tablet, mobile phone, or other device whenever you visit or interact with the Crayola Canada Properties. Usage Information may include, but is not limited to:
- Your IP address, mobile device identifier and other unique identifiers
- Device information, including device model, operating system version, device date and time, mobile network information
- Geolocation of your device
- How you use and interact with the Crayola Canada Properties, including your search terms, pages you visit, content you watch, and your preferences.
Usage Information may be collected through the use of the following technologies:
- Cookies and Local Storage. Cookies and local storage are data files placed within a browser on a device when it is used to visit the Crayola Canada Properties. Certain web browsers and browser add-ons may provide additional local data storage mechanisms. Cookies and local storage can be used for a variety of purposes, including to store a unique identifier for your device that recognizes your device as you visit the Crayola Canada Properties or other websites or online services, and to remember your preferences. Most browsers provide you with the ability to disable, decline, or clear cookies and local storage; however, if you disable cookies you may find this affects your ability to use certain parts of the Crayola Canada Properties. For more information about cookies please visit https://www.aboutcookies.org.
- Web Tags. Small graphic images or other web programming code (also known as 1×1 GIFs or clear GIFs) may be included in our web pages and email messages. These and similar technologies may be used for a number of purposes, including to count visitors to the Crayola Canada Properties, to monitor how users navigate the Crayola Canada Properties, to count how many of our email messages were opened, or to count how many particular products were viewed. The information we collect through this technology may include the first date and time you open our e‑mail, and whether you click any links included in our e‑mail.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Crayola Canada Properties, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider or business partner, is active only while you are connected to a Crayola Canada Property, and is deactivated or deleted thereafter.
Information from Third Parties. We may receive information about you from third parties, such as business partners (including companies that assist us with online advertising and analytics), other customers of the Crayola Canada Properties (such as when they provide your information to send you one of our products), data providers who enhance the information we have about you, and sources of publicly available information.
Social Media. We may host or facilitate interactions with social media platforms, like Facebook, Twitter, YouTube, Pinterest, and Instagram. When you interact with social media through the Crayola Canada Properties, we will receive information about you from the social media service and you will be choosing to share information about your interactions with Crayola Canada with that social media service.
If you choose to post information to a third-party platform, that information may be public.
5. How We Use Your Information
We work hard to get to know you so that we can customize and personalize our services to you.
- Allowing you to use and interact with the Crayola Canada Properties and the features we offer, including processing your transactions, account registration, and other features;
- Recognizing you across devices including in connection with online advertising;
- Identifying your preferences, learning and anticipating your needs, and tailoring our content, products, and services to you, including advertising, recommendations, promotions, and offers we display to you, both online and offline;
- Providing information on products/services we think you may be interested in, including special offers and promotions from us, our advertisers, and third-party partners;
- Responding to your requests for information and providing customer service;
- Verifying your identity, including verifying that your email address is valid, for purposes such as product reviews and fraud prevention;
- Improving our products, services, and marketing endeavours;
- For internal business purposes, including operating the Crayola Canada Properties, improving our products, services, and marketing endeavours, and resolving technical issues reported about the Crayola Canada Properties;
- Contacting you regarding your use of the services and, in our discretion, changes to our policies;
- Facilitating your job search, processing your employment application, and preparing related governmental and internal statistics reports;
- Complying with the law and protecting the safety, rights, property, or security of Crayola, the Crayola Canada Properties, consumers, and the general public, including investigating and preventing fraud, illegal activities, and activities that violate our policies;
- Upon notice to you at the time of collection or use of a feature, or otherwise with your consent.
6. How We Share Your Information
We may aggregate, de-identify, and/or anonymize any information such that such information is no longer linked to your personal information. We may share this non-personal information with third parties for any purpose, for advertising, research and marketing purposes.
Personal information submitted to Crayola Canada is kept confidential unless disclosed in accordance with your express consent or legal requirements. In any event, any personal information provided on any Crayola Canada platform by a user is voluntary. Please note that revoking your consent may result in not being able to access or utilize certain Crayola Canada features, programs, or services.
Personal information provided by Crayola Canada users will not be sold, shared, or rented to outside organizations unless in accordance with your consent, except as otherwise set out herein. Crayola Canada reserves the right to contact any user at any time to forward information, respond to questions, or provide notification of any changes to our services or our policies.
At Your Request and When You Post Content Publicly. We may share information when you direct us to do so. For example, you may be presented with an opportunity to receive marketing offers from a third party, or you may choose to write a product review, share a wish list, ask a question, or engage with a social media service or third-party application or feature, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
Affiliated Third Parties. We may share your information with Crayola, LLC, and its and our parents, affiliates, subsidiaries and divisions for business, analytical, and operational purposes. Crayola Canada will ensure that any such recipient only collects, uses, and discloses personal information in accordance with its privacy policies, which will contain terms and conditions that are at least as protective as those set forth in this Policy.
Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, or other promotions (any of which, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules (such as on a winner’s list).
Employment Applications. If you apply for a job through the Crayola Canada Properties, we or our service provider(s) may ask you to provide self-identifying information, such as your name, address, phone number, and employment-related information (such as that contained in a resume, cover letter, or similar employment-related materials). Providing such self-identifying information is voluntary, but if you do provide such information, we and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints. Please note that we may utilize a careers portal that is operated by a third party, in which case, you use of the careers portal will be subject to the third party’s privacy practices as disclosed on the portal, and not to this policy.
Business Transactions. We may disclose your information in connection with a corporate transition such as a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, including during the course of any due diligence process. By providing your personal information, you agree that we may transfer such information to the other entity in such a transaction without your further consent.
For Administrative and Legal Reasons. We reserve the right to use or disclose any information as needed to satisfy or fulfill our obligations under any law, regulation, or legal request; to protect the integrity of the Crayola Canada Properties; to fulfill your requests; to cooperate in a law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual property infringement; to protect and defend the legal rights and/or property of Crayola Canada and any of our corporate parents, subsidiaries, affiliates, and shareholders, or the Crayola Canada Properties, any of its users, or any other party; or, in an emergency, to protect the health and safety of users or the general public.
7. Third-Party Advertising and Analytics
Crayola Canada works with third-party business partners, including online advertising companies, ad agencies, and analytics providers to serve Crayola ads online and to provide us with information regarding the use of the Crayola Canada Properties and the effectiveness of our advertisements. Crayola Canada allows these companies to place tracking technologies like cookies and web tags on our Crayola Canada Properties, and they may otherwise collect or have access to Usage Information and other information about you. Some of these parties may collect personal information over time when you visit the Crayola Canada Properties or other online websites and services. We may share information, typically information that has been aggregated or de-identified, Usage Information, and location information with third party advertising companies, analytics providers, and other third parties, including for the purpose of serving you more relevant ads on and off the Crayola Canada Properties.
We may use a variety of companies to serve our advertisements. Some of these companies are members of the Digital Advertising Alliance of Canada (DAAC), which provides an opt-out mechanism for participating companies located at: https://youradchoices.ca/ You may be able to opt-out from interest-based advertising on your mobile device through your mobile device settings.
Mobile devices may contain settings that allow you to disable tracking advertising and/or analytics. In addition, the digital advertising industry has provided the ability for mobile users to register their intent not to receive targeted advertising. See https://youradchoices.ca/en/tools for more information.
Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online.
8. Your Choices About the Information We Collect
We may provide you with the option to update your information or to opt out of marketing communications through the profile and/or preferences section of your account. In addition, you may opt-out of marketing communications as set forth below.
Text Messages. If you sign up to receive SMS or MMS messages from Crayola, you may unsubscribe by replying “STOP.”
Push Notifications. We may send promotional and non-promotional push notifications or alerts to your mobile device, and may in some cases do so based on your device’s location or physical proximity to a beacon. You can elect to stop receiving those messages by changing the notification settings on your mobile device.
9. Your Rights and Access
Accuracy. Crayola Canada, to the best of its ability, will strive to collect and maintain the most accurate personal information available.
Right to Access. You have the right to access personal information that Crayola Canada processes about you. You can request from us information about:
- the personal information we hold about you;
- the categories of personal information concerned;
- the purposes of the processing;
- details to whom your personal information has been/will be disclosed;
- how long we retain your personal information;
- if we did not collect the information directly from you, information about the source; and
- how to lodge a complaint with the correct supervisory authority.
Right to Request the Update and Correction of Inaccuracies. You have the right to request the update and correction of inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request the updating and correction of inaccuracies in your personal information we have in our custody or control by emailing us at the contact information set out in Section 15 below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Right to Request Deletion. You have the right to request that we delete your personal information in accordance with applicable laws.
10. Security and Breach
Crayola Canada takes commercially reasonable steps designed to secure your personal information; however, no data transmission over the Internet, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. Crayola Canada cannot ensure or warrant the security of any information we collect. You use the Crayola Canada Properties and provide us your information at your own risk. Mail, voice communications, faxes, and data transmissions over the Internet are all susceptible to possible loss, misrouting, interception, and misuse of the information being communicated or transmitted. You can prevent unauthorized access to your account and personal information by selecting and securing your access password properly and limiting access to your computer, device, and browser. You should always log out after accessing your account.
Crayola Canada will comply with all applicable laws, and in so complying provide Crayola Canada users with reasonable assistance, with respect to any unauthorized use, access, or disclosure of personal information.
Crayola Canada only retains personal information for as long as it is necessary for the purposes for which it was collected. When personal information is no longer required for these purposes, it is securely destroyed or deleted. For further details on our data retention periods, please contact us. Where you have consented for us to use your details for direct marketing, we will keep this data until you notify us or otherwise withdraw your consent.
12. Third-Party Content and Links
The Crayola Canada Properties may contain content that is served by someone else or links to third-party content or websites. Crayola Canada does not control this content or these sites. The third-party operators and content providers use their own cookies or other tracking technologies, and they may independently collect information from or about you. Crayola Canada is not responsible for the privacy practices employed by any third party.
13. Consent to Transfer
As set forth in Section 7 above, we may share your personal information with Crayola, LLC, which is based in the United States. In addition, some Crayola Canada Properties (or portions thereof) may be hosted by servers located in the United States. By using the Crayola Canada Properties or providing us with any information, you fully understand and unambiguously consent to this transfer to, and processing, usage, sharing and storage of your information in the United States and in other jurisdictions, for which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to the laws in those jurisdictions. Your information will also be disclosed to third parties as described in the “How We Share Your Information” section above.
14. Access, Questions, and Concerns
If you have any questions or comments about this Policy, if you wish to access, update, and/or correct inaccuracies in your personal information, or if you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information, you may contact us at firstname.lastname@example.org