Privacy Policy 

Last Revision: May 31, 2024 

The purpose of this privacy policy (the “Policy”) is to inform you about Trace the Lace (“us”/”our”/”we”) practices relating to the collection, use and disclosure of your Personal  Information (as defined below). Your Personal Information may be collected by us through your  navigation of Trace the Lace’s website located at tracethelace.ca (the “Website”) and/or through  any communications you (“User”) may have with us. This Policy also explains how you can  contact us if you have questions about our Policy or if you would like to make a change to any  information that we may be holding about you. 

The application of this Policy is subject to applicable laws, including legislation, regulations and  the orders or lawful requests of any courts or legal authorities. 

By becoming a User of our Website, you consent to the collection, use and disclosure of your  Personal Information. We strongly recommend that you read this Policy carefully and retain it for  future reference. This Policy may change from time to time (see Changes to Our Privacy Policy below) so please check this Policy periodically for updates. Your continued use of this Website,  after we make changes to it, indicates that you accept and consent to those changes. We will  notify you in advance of any material changes to this policy and obtain your consent to any new  ways that we collect, use and disclose your Personal Information. 

Personal information we collect 

For the purpose of this Policy, “Personal Information” means any information, recorded in any  form, about an identifiable individual, or an individual whose identity may be inferred or  determined from such information, that can be used on its own or with other information to identify,  contact or locate a single person, but does not include your name, title or information that is  publically available, such as business contact information or information found in a telephone  directory. 

We collect our Website User’s Personal Information in order to effectively provide our Website to  our Website Users and to further our mission, which can be found here. This information includes  but is not limited to contact information (such as names, mailing addresses, e-mail addresses and  telephone numbers), and details of transactions you carry out through our Website, any identifier  we may use to contact you, records and copies of your correspondence with us and your  responses to surveys that we might ask you to complete for research purposes. 

As you navigate through and interact with our Website, we may also collect certain information  about your equipment and browsing actions and patterns, including but not limited to: 

• Details of your visits to our Website, including traffic and location data, web pages and  products viewed, websites or search terms which referred you to our Website, logs and other  communication data and the resources that you access and use on our Website; and 

• Information about your computer and Internet connection, including your IP address,  operating system, browser type, time zone and pre-existing cookies installed on your device. 

How we collect your Personal Information

We use different methods to collect your Personal Information, including through: 

• Direct interactions with you when you provide it to us, for example, by filling in forms or  corresponding with us by phone, email, on the Website or otherwise; 

• Automated technologies such as cookies, web beacons and log files; and • Third parties or publically available sources, such as social media platforms. 

A “cookie” is a small file placed on the hard drive of your computer. You may refuse to accept  browser cookies by activating the appropriate setting on your browser. However, if you select this  setting you may be unable to access certain parts of our Website. Unless you have adjusted your  browser setting so that it will refuse cookies, our system will issue cookies when you direct your  browser to our Website. Please note that because there is no consistent industry understanding  of how to respond to “do not track” signals, we do not alter our data collection and usage practices  when we detect such a signal from your browser. 

“Web beacons”, “tags” or “pixels” are small electronic files that permit us to count Users who have  visited pages of our Website and for other related statistics (for example, recording the popularity  of certain Website content and verifying system and server integrity). 

“Log files” allow us to track actions which occur on our Website and to collect data including your  IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. 

How we use your Personal Information 

We use the Personal Information we collect from you to: 

• Present our Website and its contents to you; 

• Facilitate communications between us; 

• Provide you with the information that you request from us; 

• Carry out our obligations or to comply with legal requirements; 

• Screen for potential risk or fraud; 

• Improve our Website; measure or understand the effectiveness of the advertising we serve  to you and others, and to deliver relevant advertising to you; 

• Estimate our audience size and usage patterns and analyze trends and track movements  around our Website; 

• Gather demographic information about our User base; 

• Store information about your preferences, allowing us to customize our Website to provide  you with a personalized experience; 

• Recognize you when you return to our Website; 

• Fulfill the purposes for which you provided the information or that were described when it  was collected; or 

• Fulfill any other purpose with your consent. 

The Personal Information that we collect may be assigned to a successor entity in connection  with a corporate merger, consolidation, sale of assets or other corporate change respecting us or  our Website. 

If you have any questions about how we use your Personal Information, please contact us at info@tracethelace.ca.

When we disclose your Personal Information

We disclose Users’ Personal Information: 

• As required or authorized by law or by order or requirement of a court, administrative  agency or other governmental tribunal; 

• Where we believe, upon reasonable grounds, that it is necessary to protect the rights,  privacy, safety or property of an identifiable person or group, including exchanging  information with other companies and organizations for the purposes of fraud protection; 

• Where it is necessary to permit us to pursue available remedies or limit any damages that  we may sustain; or 

• Where the information being disclosed or used is in the public domain. 

We may also disclose your Personal Information to third parties in order to carry out our objectives  listed in “How we use your Personal Information” above. For example, we use Google Analytics  to help us understand how our Users use our Website. You can read more about how Google  uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can  opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy,  we will notify you and/or obtain your consent as required under applicable privacy laws. Where  we are obliged or permitted to disclose information without consent, we will not disclose more  information than is minimally required in the applicable circumstances. 

Knowledge and Consent 

When you voluntarily provide us with your Personal Information, we will typically seek consent for  the use or disclosure of such Personal Information at the time of collection. In certain  circumstances, consent may be sought after the information has been collected but before use  (for example, when we want to use information for a purpose not previously identified). 

The form of consent that we seek, including whether it is express or implied, will largely depend  on the sensitivity of the Personal Information and the reasonable expectations of the individual in  the circumstances. When you fill out a form on our Website, for instance, you imply that we may  use that information for the purpose for which you filled out the form.  

We keep a record of its Website Users’ history with us. By using our Website, you acknowledge  that we may keep this record and consent to such retention. 

You may withdraw consent to the collection, use or disclosure of your Personal Information at any  time, subject to legal restrictions (such as information kept to protect us from liability) and  reasonable notice. If you wish to withdraw your consent, please contact us. We will inform you of  the implications of withdrawing your consent as appropriate. 

How we protect your Personal Information  

The safety and security of your Personal Information is very important to us. While we cannot  guarantee complete protection of your Personal Information, we follow commercially reasonable  practices to protect Personal Information collected from you against accidental loss and  unauthorized access, use, alteration and disclosure. 

Because the transmission of information via the Internet is not completely secure, any  transmission of Personal Information is at your own risk. We are not responsible for circumvention  of any privacy settings or security measures contained on our Website. Your Personal Information may be unencrypted and may be transmitted over various networks and be subject to changes in  order to conform and adapt to technical requirements of connected networks or devices. We urge  you to be cautious about giving out information in any public areas of our Website or during the  use of our Services. 

Retention of your Personal Information 

Except as otherwise permitted or required by applicable law or regulation, we will only retain your  Personal Information for as long as is necessary to fulfill the purposes for which we collected it,  including for the purposes of satisfying any legal, accounting or reporting requirements or to  protect us from liability in the event of a dispute.  

Unless you explicitly withdraw your consent, we will retain your name and contact information so  that we may archive your participation. When you explicitly withdraw your consent to us retaining  your Personal Information, or if your Personal Information is no longer necessary or relevant for  the identified purposes or is not required to be retained by applicable laws, we will take steps to  have it deleted, destroyed, erased, aggregated or made anonymous. We reserve the right to use  anonymous and de-identified data for any legitimate business purpose without further notice to  you and without your consent.  

We use reasonable business practices to ensure we have adequate controls, schedules and  practices for information, retention of records and destruction, which apply to your Personal  Information. We will make reasonable business efforts to comply with a request to delete your  Personal Information as long as technological restraints or legal constraints do not limit our ability  to fulfill the deletion request. Where a request for deletion of Personal Information is declined, the  individual making the request will be provided with the reasons for declining the request. 

Changes 

We reserve the right to modify this Policy at any time. The Policy posted on the Website shall be  deemed to be the Policy in effect. A current Policy can be obtained by contacting us. If we make  any material changes to this Policy regarding how we treat our users’ Personal Information, we  will notify you through a notice on our Website homepage. We also include the date the Policy  was last revised at the top of the Policy.  

You are responsible for ensuring that we have an up-to-date, active and deliverable email address  for you and for periodically visiting our Website and this Policy to check for any changes.  

Correcting or Updating your Information 

It is important that the Personal Information we hold about you is accurate and current. Please  keep us informed if your personal information changes. By law you have the right to request  access to and to correct the Personal Information that we hold about you. 

You may contact us if you would like to review, verify, correct or withdraw consent to the use of  your Personal Information. We may request certain Personal Information for the purposes of  verifying the identity of the individual seeking access to their Personal Information records. We 

may not accommodate a request to view or change information if we believe that: 

• The identity of the person requesting access cannot be confirmed; 

• The Personal Information is not readily retrievable, and the burden or cost of providing it  would be disproportionate to the nature or value of the Personal Information; • The requested Personal Information does not exist, is not held or cannot be found; • Disclosure of the Personal Information would compromise the confidentiality of another  individual or threaten the safety of another person; and/or 

• Non-disclosure of the Personal Information is required or permitted by law. 

Where a request for access or alteration of Personal Information is declined, the individual making  the request will be provided with the reasons for declining the request, subject to any legal or  regulatory restrictions. 

Links to Other Websites 

Our Website may contain links or references to other websites and services owned or operated  by third parties. These third-party platforms and websites are not governed by this Policy. This  Policy does not extend to the collection of Personal Information or Payment Information by third  parties, and we are not responsible for the privacy practices, policies or actions of third parties.  When visiting third party websites or platforms, whether linked to our Website or otherwise, you  do so at your own risk, and you assume all responsibility associated with the same. We encourage  you to review the privacy policies and terms and conditions of each website and platform visited  prior to using them or disclosing Personal Information or Payment Information to third parties. 

Contact us 

If you have questions about our treatment of your Personal Information or compliance with this  Policy, you may contact us by e-mail at info@tracethelace.ca.