Voilà by Sobeys Privacy Policy

Voila by Sobeys and its direct and indirect subsidiaries, parents and affiliates (collectively, “Sobeys”) respect the privacy of each customer and prospective customer (“Customer”). Voila by Sobeys is committed to protecting all personal information collected from Customers.

This Voila by Sobeys Privacy Commitment (the “Privacy Commitment”) complies with all applicable federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (Canada).

This Privacy Commitment is intended to assist Customers in understanding the purpose for collection by Voila by Sobeys of personal information and how personal information is used, protected, stored and disclosed by Voila by Sobeys and its employees, agents, partners participating in Program(s) from time to time (“Partners”), and any other authorized third party who may receive Customers’ personal information.

Responsibility

Voila by Sobeys is responsible for all personal information in its custody or under its control. Personal information is any information about an identifiable individual, including but not limited to a Customer’s name, home address, email address, telephone number, date of birth and purchasing information (in this Privacy Commitment referred to as “Personal Information”).

Voila by Sobeys is accountable to Customers for the Personal Information it entrusts to its consultants, employees, agents, Partners, and authorized third parties, including but not limited to advertising agencies, marketing agents, data processing and storage companies or organizations which provide administrative and support services to Voila by Sobeys. Such persons to whom Personal Information is entrusted by Voila by Sobeys are sometimes referred to in this Privacy Commitment as “Authorized Disclosees”.

Voila by Sobeys has established policies and procedures to ensure that the obligations set out in this Privacy Commitment are complied with by Authorized Disclosees.

Voila by Sobeys has established appropriate technological, physical and contractual security measures to help protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information.

A Privacy Officer has been appointed by Sobeys to receive, investigate and respond to complaints, and to facilitate the implementation of this Privacy Commitment. Any concerns or inquiries may be directed to the Privacy Officer at the contact address which appears at the end of this Privacy Commitment.

Purpose

Voila by Sobeys collects, uses and discloses Personal Information for the following purposes (the “Purposes”):

1. To operate its businesses, including without limitation:
- to communicate with Customers regarding orders, purchases or any concerns or queries the Customer may have;
- to communicate with Customers regarding any changes to this Privacy Commitment or to Programs and their operation;
- to ensure Customers are appropriately awarded points or their equivalent in accordance with the rules of the applicable Program and receive reward redemptions in accordance with applicable Program Rules and that rewards records are appropriately maintained;
- to provide services, rewards, products and benefits to Customers and to enable them to participate in contests;
- to understand and analyze the interests, needs and preferences of Customers;
- to develop, enhance, market and/or provide products and services for Customers, customers and potential customers;
- to verify Customers’ identity, when required or desirable for transactional purposes, so as to reduce fraud or errors in transaction processing;
- to comply with applicable legislation and regulatory requirements; and
- for investigation and law enforcement purposes.
2. To communicate with Customers regarding promotions, contests, offers, incentives, rewards, surveys, questionnaires and other pertinent matters such as but not limited to products and services under the Programs or available through Partners that may be of interest to the Customers.

Voila by Sobeys also collects Personal Information from (A) individuals when they apply for employment through a Voila by Sobeys website, or otherwise, and uses this Personal Information for the purpose of processing and responding to such application, and (B) prospective and current franchisees and affiliated merchants and their principals, and uses this Personal Information for the purpose of processing and responding to franchise and affiliated merchant applications and in ongoing dealings with such parties. In this Privacy Commitment, references to “Customers” also apply to the individuals referred to in this paragraph with any changes necessary in the circumstances.

Partners may collect Personal Information on behalf of Voila by Sobeys for the purposes identified in this Privacy Commitment.

Voila by Sobeys does not collect Personal Information from Customers other than for the purposes identified in this Privacy Commitment, except where required or permitted by law.

Voila by Sobeys collects Personal Information from Customers in several ways, including but not limited to, at the time of enrolment in a Program, when a purchase, return or Program redemption is made by a Customer, through Partners, through online use of a Voila by Sobeys or Program website, through Customer interaction with customer services offered by Voila by Sobeys and/or Program(s), through surveys or questionnaires conducted by or on behalf of Voila by Sobeys or a Partner and through contests entered by a Customer.

Personal Information collected regarding the preferences, needs and interests of Customers may be used to determine which Customers may be most interested in products or services offered by Voila by Sobeys or its Partners.

Personal information may be utilized to communicate with Customers regarding promotions, contests, offers, incentives, rewards, surveys, questionnaires and other pertinent matters such as products and services, as referenced in section 2 of the Purposes, above. Customers may not wish to receive such communications. This preference may be communicated to Voila by Sobeys at the time of enrolment, or any time afterward by contacting Voila by Sobeys through the “contact us” or equivalent link available on the relevant website, or as indicated at the place of enrolment. Such revocation will not affect the Customer’s privileges or ability to participate in a Program, nor will it prevent the provision of periodic statements as to the Customers’ point or similar balances in a Program.

Consent

Voila by Sobeys will not collect, use or disclose Personal Information about a Customer without the consent of the Customer, except where required or permitted by law, and only by legal and reasonable means.

Consent may be obtained at the time of enrolment in a Program, through survey and questionnaire forms, through a website or verbally during a conversation with a Customer.

Consent may be either express or implied. Consent will be implied, for example, when a Customer participates in a Program by collecting and redeeming points. In certain circumstances express consent may be required. In these circumstances Voila by Sobeys will seek express consent which may be given verbally, in writing or through electronic correspondence.

Voila by Sobeys will communicate with Customers regarding any changes to this Privacy Commitment. Such communication may be in the form of written or electronic correspondence, published on a Voila by Sobeys website, or by any other reasonable means of communication.

From time to time Voila by Sobeys may identify new purposes for the use or disclosure of Personal Information. Any new purpose will be communicated to Customers by way of a Voila by Sobeys or Program website or other appropriate manner, and consent (which where appropriate may be implied by continued Program participation by a Customer) will be obtained from Customers prior to any such use or disclosure, unless such use or disclosure is required or permitted by law.

Limitation

Voila by Sobeys will only retain Personal Information to the extent necessary for the purposes identified in this Privacy Commitment.

Disclosure

Personal Information of a Customer will not be disclosed to Partners for purposes other than the administration of the applicable Program unless a Customer provides consent to such disclosures. Where applicable, this consent may be communicated to Voila by Sobeys at or following the time of enrolment, and may be changed at any time afterward, by contacting Voila by Sobeys through the “contact us” or equivalent link available on the relevant website or at the place or enrolment. Revocation of such consent will not affect the Customer’s privileges or ability to participate in the relevant Program.

Personal Information may also be disclosed to Authorized Disclosees. Any party to which Voila by Sobeys discloses Personal Information must sign a confidentiality agreement or other legal contract which requires any such party to only use the information disclosed to them for the purposes as explicitly set out in the agreement.

From time to time Voila by Sobeys may disclose aggregated data to third parties. Aggregated data disclosed by Voila by Sobeys do not contain Personal Information or other information regarding identifiable individuals. Voila by Sobeys does not share, give, rent or sell Personal Information to any third parties other than Personal Information shared between Voila by Sobeys and Authorized Disclosees or as otherwise provided in this Privacy Commitment. In certain circumstances, Voila by Sobeys may be required by law to disclose Personal Information.

Voila by Sobeys may be involved in the sale, transfer or reorganization of some or all of its businesses at some time in the future. As part of that sale, transfer or reorganization, Voila by Sobeys may disclose Personal Information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of Personal Information in a manner that is consistent with this Privacy Commitment.

Accuracy

Voila by Sobeys will take reasonable measures to ensure Personal Information collected is accurate and complete. Voila by Sobeys will update its records regarding Customers based on the information communicated directly or indirectly to Voila by Sobeys by Customers or Partners. In order to ensure Voila by Sobeys’ records are as complete and accurate as possible, Customers are responsible for informing Voila by Sobeys of any relevant changes to Personal Information, such as a change of name, a change of address, or a change in any other pertinent information. Customers may request rectification of inaccurate or incomplete records where it is demonstrated that the records maintained by Voila by Sobeys are deficient. When a request has been made to rectify any inaccuracies or discrepancies, Voila by Sobeys will promptly correct, add or delete its records in order to correct any deficiency and will provide confirmation of the correction to the Customer. Where a Customer is not satisfied with the response provided to an application for access or rectification, the Customer may file a complaint with the Sobeys Privacy Officer.

Access

Upon request, Customers are entitled to examine their Personal Information collected and held by Voila by Sobeys and to be informed of the use and disclosure of Personal Information, except as prohibited by law. Where Voila by Sobeys is unable to provide access to all the Personal Information it holds about a Customer, the reasons for denying access will be communicated to the Customer. The primary records containing Customers’ Personal Information are maintained in Stellarton, Nova Scotia, the Greater Toronto Area, Ontario and at data processing and storage locations of Authorized Disclosees in the United States. Voila by Sobeys will take precautionary measures in an effort to prevent fraudulent or unauthorized requests for access. Where Voila by Sobeys receives a request from a Customer to examine Personal Information collected and retained, Voila by Sobeys will respond to the request within 30 business days.

Transparency

Voila by Sobeys will ensure that its Privacy Commitment, policies, rules, practices and procedures concerning the management of Personal Information are readily accessible to Customers. Copies of this Privacy Commitment may be obtained at any time by request directed to the Sobeys Privacy Officer. This Privacy Commitment is also available on the Program website or may be emailed to a Customer upon request.

Questions or Concerns

If you have questions or concerns about our Privacy Commitment you can contact our company’s Privacy Officer at the address provided below.

Complaints Regarding Non-Compliance

Voila by Sobeys has appointed a Privacy Officer to address any questions, concerns or complaints regarding compliance with this Privacy Commitment by any party.

The Voila by Sobeys Privacy Officer may be contacted as follows:

Sobeys Privacy Officer – 115 King Street, Stellarton, Nova Scotia B0K 1S0

Email: info@voila.ca

Voila by Sobeys will investigate all formal complaints and will respond within 30 business days after receipt of written complaint. If the complaint is reasonable, Voila by Sobeys will take suitable measures to address the complaint.