This Electronic Privacy Policy (this “Privacy Policy”) governs the receipt, collection, storage, use, transmission and disclosure of personal information by The Brick Soap Company, Inc., a corporation incorporated pursuant to the laws of the State of Delaware, and its employees, agents and representatives (collectively, “we”, “us, “our” or “The Brick”) as provided or delivered by or otherwise belonging to the customer, visitor or member to the Site (as defined below) or recipient of any Services (as defined below), whether for their own account or as agent or representative of another person or on behalf of a corporation or unincorporated organization (collectively, “you”, “your” or the “user”).
For the purpose of this Privacy Policy:
Protecting a user’s privacy is paramount to The Brick. To accommodate any concerns with how personal information is protected, The Brick has created this Privacy Policy, which articulates how The Brick collects, uses and discloses personal information obtained by The Brick when users are visiting the Site, utilizing the Services, or communicating with The Brick via Brick Communications.
This Privacy Policy DOES NOT apply to personal information collected from offline resources and communications, except in cases where such personal information is consolidated with personal information collected by The Brick. This Privacy Policy DOES NOT apply to information and communications you may post online on the Site or any page or account maintained by The Brick on any social media or other online platform. This Privacy Policy DOES NOT apply to third-party online resources to which the Site may link, where The Brick does not control the content or the privacy practices of such resources.
The Brick reserves the right to alter or modify this Privacy Policy from time to time in its sole and absolute discretion. By using the Site, you acknowledge and agree to be bound by the provisions of this Privacy Policy. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY OR ANY OF THEM, YOU SHOULD IMMEDIATELY CEASE USING THE SITE AND ANY SERVICES.
What is Personal Information?
Various jurisdictions have laws which apply to the protection of personal and private information. The Brick abides by the laws and standards set by Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). In accordance with The Brick’s Terms of Service https://thebricksoap.com/terms-of-service/, the terms and conditions applicable to your use of and access to the Site and the provision of the Services shall be governed by the laws of the Province of Ontario, Canada, and the federal laws of Canada applicable therein. Accordingly, this Privacy Policy and the receipt, collection, storage, use, transmission and disclosure of Personal Information (as defined below) and any other information or data you may provide are also governed by laws of the Province of Ontario, Canada, and the federal laws of Canada applicable therein.
Personal Information is defined in PIPEDA as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card or information that is available in public records. Personal Information includes, but is not limited to, a user’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, interests, browsing preferences, web logs, Internet protocol addresses, network and server particulars, and/or other information relevant to the Site, promotional and marketing activities.
Consent
By using the Site, the user consents to the collection, use, and disclosure of the user’s personal information and other data in accordance with this Privacy Policy. If the user does not consent to this Privacy Policy, as set out herein, the user must immediately cease use of the Site. Please note that the user’s access and continued use of the Site will be deemed as consent by The Brick.
Any personal information collected or disclosed without the consent of a user will only be collected or disclosed in limited circumstances that are expressly permitted by law. For example, privacy legislation permits the collection or disclosure of personal information in certain circumstances where there is a concern for health and safety, or in an emergency.
A user may withdraw their consent to allow The Brick to collect personal information; however The Brick may still be required to maintain certain records to comply with applicable laws.
If a user withdraws or limits its consent for The Brick to collect or disclosure personal information, The Brick may be limited in its ability to provide the Services – as this may limit The Brick ability to access or use the Site.
Importantly, this Site is intended for users who are over the age of majority in their jurisdiction (usually, 18 years of age). Persons who are under the age of majority should not provide any personal information directly to The Brick, and The Brick will require a parent or guardian to communicate directly with The Brick for all services related to minors.
How is Personal Information collected?
The Brick collects your personal information and other data to provide and promote the Services, as well as to provide related services like customer support to you or to comply with applicable law. If you do not provide the personal information we ask for, it may delay or prevent us from providing the Service or support to you. The Brick retains personal data for so long as reasonably necessary. Our information processing activities include conducting our business, customer communications and support, user verification, payment processing, shipping, quality management services, Service maintenance and improvements, and complying with legal requirements.
Information You Provide
The Brick collects the following categories of personal information that you provide to us: (1) contact information including your name, email address, and mailing address; (2) authentication information, including the user name and password that you use to register an account on the Service; (3) financial information for payment processing purposes; (4) user content, including survey responses, comments, reviews, questions, and suggestions; (5) personal characteristics including age range, date of birth, and gender; (6) personal preferences including product preferences, online preferences, and interests; and (7) health-related information that we may learn from your responses to questionnaires or in connection with notifying us of an adverse reaction to any of our products.
Information Collected from a user’s Computer or other Electronic Device
The Brick collects information from a user’s computer and other electronic devices when a user accesses the Site and other online resources. The information that is collected during this process includes but is not limited to a user’s Internet Protocol (IP) address, domain name, browser type, date and time of a user’s request and information provided by tracking technologies, such as cookies and single-pixel tags, which are defined below.
If a user is accessing the Site from a mobile device, The Brick may collect information about the user’s device, such as a user’s device ID and device type, as well as usage information, use of mobile websites and other mobile resources.
“Cookies” are small text files placed on a user’s hard drive that assists The Brick in providing a customized browsing experience. Cookies contain a unique identification number that identifies a user’s browser, but not the visitor, to The Brick’s computers each time a user visits the Site. The Brick uses cookies to make navigation of the Site easier for visitors and to facilitate efficient registration procedures. If a user is concerned about cookies, most browsers permit individual to refuse to accept all cookies or to notify users when a user has received a cookie. However, a user should note that if the user refuses to accept cookies, the user may not be able to use some of the features available on the Site and other online resources.
“Single-pixel tags”, also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible. Single-pixel tags are used to collect information in web logs that do not identify a user personally such as web pages viewed, the web site a user came from and the advertisement the user clicked on to visit the Site. Single-pixel tags are also used to confirm whether promotional or other commercial e-mail messages that are sent via the Site are opened.
In order to properly manage the Site, The Brick may also anonymously use log information on operational systems, and identify categories of users by items such as domains and browser types. Statistics may be reported to a party assisting The Brick in offering the Site, such as webmasters.The Brick only collects personal information to the extent that it is necessary to accomplish the specific purposes for which it is being collected.
How is the Personal Information used?
The Brick, whether directly or via service providers and business partners as outlined further below, collects, uses and discloses Personal Information to better understand a user’s needs and to provide a user with better services. In particular, personal information and other user data is collected for the following reasons:
The Brick may, at its discretion (but will not be required to), remove identifying data from your personal information to be used to assess various factors, including trends in the market and demographics for the Products, other market research and analytics, regulatory compliance, and in order to improve upon our services. Personal information from which identifying data has been removed may be shared with third parties for the purposes set out above.
In certain limited circumstances, The Brick may be required to release or provide access to personal information in response to a subpoena, search warrant, court order, law, or regulation. In such case, The Brick will take all appropriate measures to ensure that users’ personal information is protected to the greatest extend possible while The Brick cooperates fully with court and law enforcement authorities in this regard.
To whom does The Brick provide personal information?
Personal information and other user data will be accessible to The Brick, and to individuals and organizations that use personal information and data gathered by The Brick, solely for purposes permitted by this Privacy Policy. Uses and disclosures of personal information and data by external individuals and organizations receiving the same from The Brick are governed by agreements that require personal information to be protected appropriately. When The Brick allows a third party service provider or business partner to have access to your personal information and data, they will only be permitted to take it or use it for purposes that are consistent with this Privacy Policy.
Third party service providers and business partners for such purposes may include corporate affiliates of The Brick within The Brick’s corporate group, transferees and prospective transferees in connection with any sale, merger, consolidation, amalgamation or other reorganization involving The Brick (including in a bankruptcy or insolvency scenario), and third party research, payment processing and transaction fulfillment, database maintenance, administering contests and special offers, technology services, deliveries, sending communications, advertising and marketing services, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, and data processing providers.
Without limiting the generality of the foregoing, the user specifically consents to The Brick disclosing personal information to external individuals and organizations strictly in accordance with this Privacy Policy, to inform such external individuals and organizations, where necessary, of possible security incidents or legal inquiries, or to assist such external individuals and organizations in investigating responding to, remedying, or preventing security incidents.
The user specifically consents to The Brick, or external individuals and organizations to which personal information and data disclosed strictly in accordance with this Privacy Policy, using personal information as follows:
Unless otherwise advised, The Brick will not share personal information except as described in this Privacy Policy and other applicable privacy notices. However, The Brick reserves the right to disclose personal information, including e-mail addresses, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by law. Except as provided in this Privacy Policy, personal information will not otherwise be shared without a user’s permission.
The user understands that The Brick may disclose personal information to external individuals and organizations, strictly in accordance with the terms of this Privacy Policy, located in countries outside of Canada whose laws provide for less protection for that member’s personal information, the user specifically consents to their personal information being transmitted to any such countries.
The user understands that The Brick may notify external individuals and organizations if The Brick becomes aware of any non-compliance with any privacy laws, including any unauthorized or unlawful collection, use or disclosure of or any accidental loss or destruction of, or damage to personal information or of any circumstances that would cause a reasonable data security professional to suspect that such collection, use or disclosure, loss, destruction, damage a non-compliance had occurred or will occur.
The Brick may disclose your personal information and data to a buyer or transferee in connection with the sale, assignment, or reorganization of its business, in which case The Brick will require any such buyer to agree to treat it in accordance with this the terms of this Privacy Policy.
Requests for Non-Disclosure
A user may withdraw their consent to The Brick’s collection, use and disclosure of personal information at any time, subject to legal and/or contractual restrictions and upon reasonable notice, by contacting The Brick via email at privacy@thebricksoap.com and providing express written direction in that regard. Please note certain personal information will be collected automatically when a user visits the Site. A user’s continued use of the Site will be deemed consent to obtain any personal information that derives from the user’s use of the Site.
How does a user limit disclosure of a user’s Personal Information?
A user may choose not to provide personal information to The Brick by electing not to enter any personal information into a form or data field, and by not using any personalized services provided by the Site or by any other online resources. However, some of the Site may only be available to users that provide personal information or request the use of personalized services.
If a user previously agreed to permit the use of personal information for marketing or promotional purposes, such user may revoke consent by following the opt-out instructions in each communication or by by contacting The Brick via email at privacy@thebricksoap.com and providing express written direction in that regard.
How does The Brick protect a user’s Personal Information?
The Brick employs physical, administrative, and technological security safeguards appropriate to the sensitivity of the information.
The Brick will take all commercially reasonable and legally required steps to protect personal information as it is transmitted from a user’s computer to the Site or other online resources and servers. The Brick will also protect personal information from unauthorized access, disclosure, alteration or destruction. The Brick ensures that all affiliates and other third parties that are retained to perform services on The Brick’s behalf and are provided with personal information are contractually required to observe this Privacy Policy. It is a user’s personal responsibility to secure a user’s own copies of any logins, passwords and related access codes used on or for the Site.
Please note, security risks on the internet cannot be eliminated, and The Brick cannot and does not guarantee that a user’s personal information will not be accessed in ways not otherwise described in this Privacy Policy.
How may a user access and correct personal information?
Users may access, update, and correct personal information in the possession of The Brick, subject to certain exceptions prescribed by law.
Upon written request submitted to The Brick by contacting us via email at privacy@thebricksoap.com and providing express written direction, The Brick will provide a user with any personal information in its possession to the extent required by law.
If a user would like to access any of its personal information, or believes that any of the personal information collected by The Brick relating to a user is incorrect or incomplete, please send notify us by contacting The Brick via email at privacy@thebricksoap.com.
Retention of Information
To comply with existing laws, and to ensure that we are able to refer to a user’s personal information when necessary, The Brick keeps records of a backup archive of all data collected. Personal information is retained by The Brick for minimum time periods required by law. When Personal information is no longer required to be maintained, The Brick will delete it, or remove personal identifying data from such information.
Other Matters
Former users
If a user ceases using the Site, or a user’s access to the Site has been terminated, The Brick may continue to use and disclose a user’s personal information in accordance with this Privacy Policy.
Terms and Conditions of Use of Site
Any applicable terms & conditions of use governing a user’s use of the Site contain important provisions, including provisions disclaiming, limiting, or excluding the liability of The Brick for a user’s use of the The Brick Site and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding a user’s use of the The Brick Site, continue to apply in addition to this Privacy Policy, such that this Privacy Policy and such terms & conditions shall apply cumulatively. Each of those provisions applies to any disputes that may arise in relation to this Privacy Policy, including any collection, use and disclosure of personal information and are of the same force and effect as if they had been reproduced directly in this Privacy Policy.
Third Party Links and Web Sites
The Site may contain links to other third party web sites or internet resources, which are not affiliated with the Site, nor provided by The Brick, and are not subject to this Privacy Policy. The user assumes any risk associated with any third party links or Sites. The Brick assumes no responsibility or liability for, or control over any third party Sites or their collection, use and disclosure of a user’s personal information.
Privacy Policy Amendments
To accommodate amendments to the Site, changing technology, and legal developments, this Privacy Policy may be revised in The Brick’s absolute discretion and without any prior notice or liability to the user or any other person. The Brick’s collection, use and disclosure of the personal information through the Site will be governed by the version of this Privacy Policy in effect at that time when the information is collected, used, or disclosed. New versions of this Privacy Policy will be posted on the Site and will be available upon request from The Brick. A user’s continued access, use and/or dealings with the Site after any amendments to this Privacy Policy, will signify a user’s consent or continued consent to the collection, use and disclosure of personal information in accordance with the revised Privacy Policy.
Compliance with Anti-Spam Laws
The Brick is committed to reducing the harmful effects of spam and related threats to electronic commerce and is working towards a safer and more secure online marketplace. Various jurisdictions have laws which regulate certain forms of electronic contact, consisting of, the sending of commercial electronic messages, the alteration of transmission data in electronic messages, and the installation of computer programs on another person’s computer system, in the course of a commercial activity. The Brick complies with the laws and standards set by Canada’s Anti-Spam Legislation (“CASL“) which came into effect July 1, 2014.
The fundamental underlying principle of CASL is that such activities may only be carried out with consent. The Brick complies with CASL and works with its affiliates, customers and partners to seek consent, as required by CASL, before communicating any commercial electronic messages.
For More Information
For more information about this Privacy Policy, please contact us privacy@thebricksoap.com.
For more information on your privacy rights, you may also contact the privacy commissioner or other governing body or authority with jurisdiction in your location. The privacy commissioner for Canada, which has jurisdiction over the privacy and anti-spam laws which The Brick adheres to as described above, can be contacted as follows:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3