Privacy Policy

PRIVACY POLICY(Last modified on August 8, 2023)

Welcome to the St. Regis website at https://stregiswines.com (the “Website”).  We are delighted that you have chosen to visit us and use the Website. This Privacy Policy (the “Policy”) covers personal information collected from you or about you when you are visiting or using the Website.

I-D Foods (the company that owns and operates the Website) takes your privacy and security of personal information very seriously. We have provided and will continue to provide a secure environment and this strict Policy that describes the limited ways your information is used and the limited access to such information. We ask that you read it carefully.

Key Elements of this Policy

Here are the key elements of this Policy so you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your personal information. By submitting any personal information to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy.

Some Terms

Before we get started with the details, here are a few terms we think you should know as you read this Policy.

“Data Protection Laws” refers to the laws that are designed to protect your personal information and privacy in the place where you live. The Data Protection Laws include: (1) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada; (2) Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (the “Quebec Privacy Act”) as amended by Law 25, that applies to our activities in Quebec; and (3) the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020, which applies to our activities in the United States. I-D Foods is committed to adhering to these and any other applicable Data Protection laws.

“Personal information” – this is information we collect from you or about you and which is defined in PIPEDA as “information about an identifiable individual” and under the Quebec Privacy Act as “any information which relates to a natural person and allows that person to be identified either directly or indirectly.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you.

Other terms and definitions used in this Policy may be found in our Terms of Use, and will have the same meaning in this Policy as they do there. There are also other definitions throughout this Policy, but they are easy to spot as they are bolded and in quotation marks.

About Us and Contacting Us

I-D Foods Inc. (“I-D Foods”) is a Canadian corporation located in Laval, Canada at the address listed below. Where this Policy refers to “I-D Foods”, it may refer to I-D Foods Inc.and / or its affiliates, subsidiaries or parent companies, and their respective shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to I-D Foods. In this Policy a Website visitor or user or any other individual for whom we hold personal information may be referred to as “you”.

Under PIPEDA, I-D Foods is an “organization” and under the Quebec Privacy Act I-D Foods is an “enterprise”.

If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can contact our Privacy Officer tasked with overseeing privacy matters for I-D Foods at the following address:

I-D Foods Privacy Officer

Andrea Felli

privacy@idfoods.com

or:

I-D Foods Privacy Officer

Andrea Felli

1800 Desserte S Autoroute 440

Laval, Québec

Canada

H7S 2E7

Your Rights

You have the following rights regarding your personal information held by I-D Foods, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. Please note that exercising certain of these rights may affect your ability to use some or all of the Website.

● The right to withdraw at any time your consent for I-D Foods to process your personal information;

● The right to have your personal information erased from I-D Foods’ records, and to have your name de-indexed if we link to any information about you (which we currently do not);

● The right to access your personal information and any relevant information around its processing and use;

● The right to have a copy of your personal information given to you in an easy-to-read format;

● The right to have your personal information corrected or updated if you believe it is inaccurate or out of date;

● The right to opt out of marketing communications we send you, at any time;

● The right to know whether I-D Foods sells or shares your personal information (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications;

● The right to restrict the collection, use and disclosure of your personal information if it is inaccurate or if our processing or use of it is against the law; and

● The right to refuse any marketing or advertising targeted at you by I-D Foods.

If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above, or refer to certain relevant sections further in this Policy.

Limited Personal information Collected from You and What We Use It For

I-D Foods limits the amount of personal information we collect to what is necessary and appropriate for the identified purposes. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.

In the table below, please find all the personal information we may collect from you directly and what we use it for. Under PIPEDA the Quebec Privacy Act, and the CCPA, we collect and use this personal information with your informed consent, and by submitting this personal information to us you acknowledge having granted this consent to I-D Foods.

Personal information Collected About You from Third Parties and What We Use It For

We generally do not get personal information about you from third parties. Exceptionally, we collect the following:

1. to the extent that advertising and analytics identifiers are generated from third parties, these may be considered personal information collected from third parties, and you can find details about that further below in this Policy; and

2. to the extent your location is considered personal information, Google Maps is used on the Website and uses your location to show you stores near you where you can purchase St. Regis Products.

Sensitive Personal information

We do not collect any of what the Data Protection Laws consider sensitive personal information from you when you use the Website, unless you voluntarily submit it to us, which we encourage you not to do.

Who We Transfer Your Personal information To

We routinely share some of your personal information with certain types of third parties who are identified in the table further below in this section along with what they do with it.

We will also share personal information with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the I-D Foods Terms of Use; (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website infrastructure or the Internet in general (such as voluminous spamming or denial of service attacks); (4) if we are required to do so under any applicable law.

We may also share personal information: (1) to a parent company, subsidiaries, joint ventures, or other companies under common control with I-D Foods (in which case we will require such entities to honour this Policy); or (2) if I-D Foods merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).

We will never share your personal information with other third parties except under these circumstances. We do not sell or rent your personal information to any third party for direct marketing purposes or any other purpose.

Email Communications and Compliance with Anti-Spam Laws

I-D Foods uses MailChimp(the “Email Service Provider”) to manage our mailing list and send out our newsletters. Personal Information is transferred to the Email Service Provider in order to manage the mailing list and for the St. Regis newsletter to be sent out properly. Your Newsletter Information is only used to send out emails; the Email Service Provider does not use this personal information for any other purpose and will not transfer or sell your personal information to any other third party. For more information, please refer to MailChimp’s Privacy Policy.

You may unsubscribe from the newsletter mailing list at any time, by following the link at the bottom of those emails.

I-D Foods’ practices in regards to its email are designed to be compliant with anti-spam laws, including but not limited to the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23) and the American CAN-SPAM Act of 2003. If you believe you have received email in violation of these laws, please contact our Privacy Officer using the contact information further up in this Policy.

I-D Foods Advertising and Opting Out

I-D Foods is continuously evaluating and modifying our use of various advertising networks, which may change from time to time. In this section you will find all the advertising networks that I-D Foods currently uses and instructions for opting out of them. You may also opt out or decline such advertising by refusing or deleting the appropriate cookie, as described further in this Policy. Furthermore, many of these networks support Do Not Track, which you can use to eliminate personalized ads.

Generally, these ad networks work by delivering you advertisements that will be of particular interest to you when you use their website and / or apps, based on your browsing and activity history interacting with the Website.

The table blow identifies the Advertising networks we currently use, as well as links and instructions on opting out. By visiting the Website or using the Website you consent to our advertising to you in this manner, understanding that you can opt out any time.

Limited Gathering of Information for Statistical, Analytical and Security Purposes

I-D Foods automatically collects certain information using the “Third-Party Analytics Program” Google Analytics, to help us understand more about our Website visitors and users and how they use the Website, but none of this information identifies you personally, except via an alphanumeric string. For example, each time you visit the Website, we automatically collect (as applicable) your IP address, browser and computer or device type, access times, the web page from which you came, the web page(s) or content you access, and other related information. We use information collected in this manner only to better understand your needs and the needs of Website visitors and Website users in the aggregate. I-D Foods also makes use of information gathered for statistical purposes to keep track of the number of visits to the Website, the specific pages on the Website, and users with a view to introducing improvements to the Website and our marketing activities.

Your IP address and other relevant information we collect using the Third-Party Analytics Program may be used in order to trace any fraudulent or criminal activity, or any activity in violation of the I-D Foods Terms of Use.

Tracking Technology ("Cookies") and Related Technologies on the Website and in Email Communications

I-D Foods uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website and in our newsletters. Cookies are small text files placed on your computer or device when you visit a website or use an internet-connected service, in order to track use of the site or service and to improve the user experience by storing certain data on your computer or device.  By visiting or using the Website you agree to their use.

Specifically, we use cookies and related technologies for the following functions:

·       to facilitate online advertising including email retargeting, as described above in this Policy;

·       to provide general internal and user analytics and to conduct research to improve the content of the Website using the Third-Party Analytics Program as described above in this Policy; and

·       to assist in identifying possible fraudulent activities.

Your browser can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:

·       Google Chrome

·       Mozilla Firefox

·       Microsoft Edge

·       Opera

·       Apple Safari

· iOS

·       Android

Please note that deleting these cookies may reduce your user experience on the Website. Furthermore, deleting cookies may prevent certain functions from working at all.

Furthermore, when we send you email communications using the Email Service Provider mentioned further above in this Policy, we use unique URLs and other tracking technologies embedded in the emails to track if you have opened the email or clicked on any links in the email.

How We Protect Your Personal information

We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal information which are necessary for each specific purpose we collect it for is used by us. These procedures prevent your personal information from being lost; or used or accessed in any unauthorised way. Examples of such procedures include restricted access to offices, training of personnel, using passwords and well-defined internal policies and information technology practices.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.

I-D Foods uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal information) secure. In addition, we use third-party vendors and hosting partners (specifically Haven Hosting Ltd., located in Ontario, Canada) to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website, and these third parties have been selected for their high standards of security, both electronic and physical.

All information, including personal information, when transferred via the Website is done with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer. You can use your browser to check I-D Foods’ valid SSL security certificate on the Website.

Supervisory Authorities and Making Complaints

If you are in Canada and you are not satisfied with the response received or the actions taken by our Privacy Officer, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website. In Québec you can make a complaint to the Commission d’accès à l’information, with the instructions for contacting them on their website.

In California you can make a complaint to the California Privacy Protection Agency, using their online form.

Data Retention

Your personal information will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will only retain your Newsletter Information for as long as you continue to consent to receive the newsletter from us.

Automated Processing

I-D Foods does not use any automated processing or decision-making processes in providing the Website.

Changes to This Privacy Policy

The date at the top of this page indicates when this Policy was last updated. Because Data Protection Laws are constantly evolving, every now and then we will have to update this Policy, which we will do no less than once per year. You can always find the most updated version at this URL. If we make significant changes to the Policy, we will always post a notice on the Website, and if we have your email address, we will also email you to tell you the Policy has been updated, and what the important changes are.

© I-D Foods Corporation. 2023