Effective Date: June 14, 2017
RONA Inc. and its subsidiaries that operate in Canada (collectively “RONA”), value and respect the privacy of customers, employees, job applicants, and suppliers. This Privacy Statement describes how RONA collects, uses, shares, retains, and protects personal information, and the choices you can make regarding your personal information. Click on any heading below to go directly to that section of the Privacy Statement.
RONA is part of the Lowe’s Companies Inc. family, a global organization with legal entities, business processes, management structures, and technical systems that cross international borders. This Privacy Statement governs the collection, use, and disclosure of “personal information,” as defined in applicable privacy legislation, collected by RONA at physical locations it operates in Canada and on RONA branded websites and domains, such as www.rona.ca, www.renodepot.com, dickslumber.com, and any other website that points to this Privacy Statement, unless a statement posted on a specific RONA website or at a RONA operated physical location states that a different privacy statement applies. This Privacy Statement does not apply to RONA stores operated by independent dealers (including any other activities by or communications from such dealers) and does not apply to other Lowe’s entities or websites, such as Lowes.com and Lowes.ca, which are governed by their own privacy statements.
All employees and those working on behalf of RONA are responsible for following this Privacy Statement. RONA has designated a Privacy Officer who is responsible for overseeing RONA’s compliance with this Privacy Statement. Please see “How to Contact Us” for information on how to contact the designated RONA Privacy Officer.
TABLE OF CONTENTS
- Collection of Personal Information in Stores or over the Telephone
- Collection of Personal Information Online
(a) Information You Provide
(b) Information Collected by Automatic Means
- RONA Private Label Credit Products
- Service Providers and Business Partners
- Legal, Enforcement, Security, and Investigation
- Sale or Transfer of Business or Assets
- Aggregate or De-Identified Data
- Corporate Group
- How RONA Obtains Your Consent
- Withdrawal of Consent
- Individual Access to and Correction of Personal Information
INFORMATION WE COLLECT
RONA may collect personal information that you provide when you:
- Purchase, rent, order, return or exchange any of our products and services online or in one of our stores;
- Request a copy of an invoice or electronic invoice;
- Request a quote, product information or special order any of our products and services;
- Request delivery, warranty or repair services;
- Contact RONA customer service representatives or other employees by phone or in one or our stores;
- Visit our website;
- Use any RONA mobile app;
- Enter into a contest or respond to one of our surveys;
- Make a credit application;
- Apply for employment or accept employment;
- Provide us with comments or suggestions; or
- Are injured, suffer or cause property damage on RONA premises.
RONA may also collect personal information from public sources and from third-parties where permitted by law. Below you will find specific information about RONA collection practices in stores and over the telephone, as well as online and in connection with a RONA private label credit products.
A. Collection of Personal Information in Stores or over the Telephone
At the point-of-sale, for most transactions we may ask for your e-mail address and your Air Miles® card or collector number, if applicable, which you may decline to provide. We may use your e-mail address to provide you with information about RONA products and services, and to invite you to join e-mail lists for specific marketing and other communications. We may use your Air Miles information to report your purchases to that program. We may also use the data to perform customer analytics and to otherwise assist us in enhancing our customers’ shopping experience.
If you use a debit or credit card for any of your purchases, RONA transmits directly to our payment processor the payment card information necessary to complete each transaction. As a general rule, we do not collect or retain full payment card data. But we may receive from the processor, and retain for our records, some truncated form of the payment card data, which may be used to help locate a prior purchase in connection with a request to return an item or to provide a refund or exchange, as well as for analysis and to comply with laws requiring RONA to retain financial records of its activities.
If you return previously purchased merchandise or request a refund or exchange, especially without a receipt, you may be asked to verify your identity and to provide your name and/or other identification information for our records. RONA collects this information for loss prevention purposes, including the detection and prevention of fraud and theft.
If you purchase or arrange for a delivery or an installation service, RONA may collect additional personal information from you to aid in providing these services. This additional information may include your name, address, personal e-mail address, telephone number(s) and shipping or installation location information. This information may also be used to perform customer analysis and to otherwise assist us in enhancing our customers’ shopping experience.
Similarly, if you have made a purchase through our websites for pick up at a RONA store, you or the person you’ve authorized to make the pick-up may be asked to provide your driver’s license or other form of identification at the store for authentication purposes – but we do not record or retain this information. This process is used for loss prevention purposes.
If you qualify for a tax exemption, RONA will collect the personal information necessary to document the exemption and satisfy the applicable taxing authorities, as well as to help identify you and retrieve your tax exempt status when you make future purchases, so that you aren’t required to repeatedly provide the same information.
If you rent a truck/trailer or other equipment, RONA may collect, on its behalf or on behalf of the owner of the trucks/trailers or other equipment, personal information to identify and contact you, such as a driver’s license and verification of age and insurance, payment information, and similar data. This information is used to comply with obligations to the owner of the truck/trailer or other equipment, determine eligibility to rent, comply with legal requirements, confirm the identity of the customer, and assist in retrieving the truck/trailer or other equipment in the event they are not returned.
If you apply for a commercial credit account with RONA (as opposed to a RONA privacy label credit card – see below), we may request a variety of personal information in order to allows us to determine whether to extend you credit and to manage your account prospectively. The personal information that may be requested by RONA in your application includes data such as your name, date of birth, address, telephone number(s), e-mail address, income, and other information necessary to confirm your identity and that of Co-Applicants or other Authorized Users of the commercial account. In addition, you may choose (but are NOT obligated) to provide your Social Insurance Number (SIN) which may expedite the processing of your application. In the event you choose to provide us your SIN, we will only use your SIN for the purposes of assessing and processing your credit application. We will not disclose your SIN to any third party except to: (i) members of our corporate group for the proposing of assessing and processing your credit application, and (ii) our third party service providers for the purposes of obtaining your credit information (generally in the form of a credit report), and storage. Your SIN will be stored in accordance with all the protections set out in this Privacy Statement. RONA solely makes the credit decisions and manages these commercial credit accounts.
RONA may conduct video surveillance and recording of its stores and other premises for security, loss prevention, and safety purposes, and to monitor in-store traffic patterns, customer counts and interests, and perform similar analytics. Where video surveillance is used, recordings are kept in a secure area. RONA policies limit access to any video surveillance to appropriate personnel, such as loss prevention employees and management. Video surveillance recordings are routinely destroyed unless they are needed for investigations of an incident or legal proceedings.
If you telephone RONA to make an inquiry, request information, provide a compliment, make a complaint, or for any other reason, RONA may ask for personal information in order to assist you. For example, RONA may collect your contact information so that it can later respond to you. RONA may also ask for information about the product or service that you purchased or about which you have expressed an interest so that it can process your inquiry and provide you with an opportunity to learn about other products or services that may be of interest to you. Calls to or from customer service centers or other phone support lines may be monitored or recorded for quality control, training, security, and analytics purposes.
B. Collection of Personal Information Online
(1) Information You Provide
When you visit RONA websites, RONA may provide you with the opportunity to become a registered online user, but will not require that you register. Similarly, you may choose to register for RONA membership programs. If you register, you will be asked to provide limited contact information and you may also sign up for e-mail newsletters. RONA may use third party companies to authenticate and validate the information you provide to RONA. Your registration information may be merged with additional information we already possess or information provided by the third parties to enhance our marketing efforts. The information you provide while visiting RONA websites may also be combined with marketing research from internal and external sources and may be used to determine informational and shopping preferences.
If you choose to purchase products online from RONA websites you generally will need to provide the following information, and potentially other specific information, so that we can fulfill your order:
- First and Last Name
- First and Last Name of person authorized to pick-up the product (if other than yourself)
- Contact Phone Number(s)
- Shipping/Billing Address
- Email Address
- Payment Information
- Air Miles® Information
RONA requests a phone number in case one of our Customer Care representatives need to reach you. RONA requests an email address because we may send transactional e-mails acknowledging receipt of your order and providing updates on the processing of your order, and potentially to request your feedback related to your shopping experience. You may also be given the choice of receiving future marketing e-mails or newsletters at the e-mail address you provide. Your order information will also be used to track and analyze shopping trends.
If you choose to apply on-line for employment with RONA, the information you provide will be provided through the RONA career portal operated for RONA by CV Manager, which collects the information on RONA’s behalf. RONA collects your personal information during the employment application process in order to evaluate your application, perform consensual background checks, and to make hiring decisions.
(2) Information Collected by Automatic Means
When you visit RONA websites, interact with e-mails from RONA, or access RONA online advertising, RONA may collect certain information by automated means, using technologies such as cookies, Web server logs, and Web beacons. This information may be used to provide a better-tailored and more personalized shopping experience, and for market research, data analytics, and system administration purposes. For instance, RONA may use this information to determine whether you’ve visited our website before, to store your preferences and settings, to provide sign-in authentication, and for compliance with our legal obligations, policies, and procedures. RONA may also collect data about your activities on our websites for use in providing advertising tailored to your individual interests, as described in Interest-Based Advertising below.
RONA websites, e-mails, and electronic newsletters may contain tags known as “Web beacons” or “single-pixel gifs,” which are small electronic images used to help deliver cookies on our sites, count visitors to our webpages, determine whether e-mails are opened, and for other operational purposes. We may work with other companies by sharing information about the use of our beacons or to place beacons on their sites or in their advertisements to let us develop statistics on how often clicking on an advertisement or product on one website results in a purchase or other action on other sites. Our webpages may also contain Web beacons from third parties, which help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other website operations. These Web beacons may allow the third parties to set or read a cookie on your computer.
E-mails from RONA may use links designed to lead you to RONA materials or third-party materials on the Web, after redirection through RONA servers. The redirection system allows RONA to change the destination URL of these links, if necessary, and to determine the effectiveness of our marketing initiatives. Such web links may also allow RONA to determine whether you have clicked a link in an e-mail, and this information about the interaction may be connected to your personal information. If you do not want RONA to collect information about the links that you click, you can choose not to click links in an e-mail that RONA sends.
RONA websites and applications generally use Web server logs to record information about your use of the services, such as your device type, operating system type, browser type, domain, system settings, and IP address, as well as the language your system uses and the country and time zone where your device is located. These logs also may record information such as the address of the Web page that referred you to our website, and other information about your interaction with our websites, such as which pages you visit. This is a common practice that supports the operation and protection of our websites and applications.
RONA may use third parties to perform certain functions on our websites, such as to provide instant surveys. Rona may also use third-party Web analytics services on our websites, such as those provided by Google Analytics, to help us analyze how users use our websites. These providers may collect various data points associated with your visits to our websites, including your IP address, and they may place cookies to help with the analysis. To learn more about Google Analytics and how to opt-out, click here.
If you choose to install a RONA mobile application on your mobile device, we may automatically collect certain details and other information about your use of the application. We may also ask to collect information about your precise location, including your location when you are within our stores. You can control and change the mobile applications’ use of your location through your device’s operating system controls and settings.
RONA may also collect information from commercially available sources to whom you have given consent to share your personal information or who provide anonymous demographic information associated with a geographic area. The information RONA collects from its commercial sources may be used along with the information RONA collects from you when you visit a RONA website or in our stores. For example, RONA may compare the geographic information acquired from commercial sources with the IP address collected when you visit our website to derive a general geographic area in order to provide you with information or promotions relevant to your geographic area.
C. RONA Private Label Credit Products
How We Use Information
We may use the personal information we collect for a range of business purposes, including to:
- Identify customers, employees and suppliers and to establish and maintain a relationship and communications with them through various channels;
- Provide customers with ongoing service (such as to process orders, payments, returns, warranties, and rebates), to complete deliveries, and to better assist customers when they visit or call us;
- Evaluate and respond to requests, inquiries, and applications;
- Conduct and administer contests, surveys, and sweepstakes;
- Provide customers with information about other RONA products and services, or those of companies with whom we are working, that may be of interest to them;
- Customize experiences in RONA stores and online, including customized advertisements and offers;
- With respect to information collected through the RONA Careers website, evaluate applications for employment and contact applicants regarding possible employment;
- Operate, evaluate, and improve RONA’s business, products, and services (including developing new products and services; managing communications; performing market research and data analytics; determining and managing the effectiveness of advertising and marketing; analyzing products, services, websites, and applications; administering websites and applications; and perform accounting, auditing, billing, reconciliation and collection activities);
- Protect against and prevent fraud and unauthorized transactions, investigate and manage claims, reduce risk exposure, and generally improve and provide security; and
Comply with and enforce applicable legal and audit requirements.
How We Share Information
We may transfer personal information to our affiliates from time to time to use in accordance with this Privacy Statement. We do not sell, trade, or otherwise transfer personal information to unaffiliated third parties (companies outside the Lowe’s family) without your consent, except as described below.
A. Service Providers and Business Partners
We may disclose your personal information to companies that provide services to us (such as providers of hosting, support, delivery, survey, printing, e-mail, data enhancement, and repair services) or that help us market our products and services. These companies may need access to information about you in order to perform their functions. In some instances, we may ask these companies to collect your personal information on our behalf. These companies are not authorized to use the information we disclose to them, or that they collect on our behalf, for any other purpose without your consent and we use contractual and other measures to ensure that such information is protected in accordance with this Privacy Statement.
With your consent we may disclose limited information about you to a third party who may also use the information for their own specific purpose. For instance, we may provide information on your behalf to a supplier in connection with warranty or product safety issues, or we may share limited information with a business partner who is jointly providing a product or service to you or is running a jointly branded promotion with us. We may also share limited information with the banks (currently Desjardins Card Services) that issue RONA private label credit products so that they may offer and service such accounts.
B. Legal, Enforcement, Security, and Investigation
We may disclose personal information about you (1) if we believe we are required to do so by law, regulation or legal process, such as a court order or subpoena; (2) as we deem appropriate or necessary in response to requests by government agencies, such as law enforcement or Police Services authorities, or tax authorities; (3) when we believe disclosure is appropriate or necessary to protect the rights, property, or safety of RONA, our customers, or others, including to prevent physical, financial or other harm, injury or loss, or to collect debt you owe; or (4) in connection with an investigation of suspected or actual unlawful activity.
C. Sale or Transfer of Business or Assets
We reserve the right to transfer personal information we have about you in the event we sell, finance, or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, or liquidation). The use of such personal information, however, would still be restricted to that outlined in this Privacy Statement.
D. Aggregate or De-Identified Data
We may share or make public aggregate or de-identified data derived from personally identifiable information. Such information, however, will not identify you or any other individual.
E. Corporate Group
We may share your information within our corporate group for the purposes contemplated in this Privacy Statement. Where we share your information within our corporate group, we use contractual and other measures to ensure that such information is protected in accordance with this Privacy Statement.
How We Retain & Protect Information
RONA retains personal information for as long as it is useful or necessary to process related transactions, maintain appropriate financial and audit records, protect RONA legitimate business interests, improve our products and services, and for as long as may be required by applicable laws.
RONA maintains administrative, technical, and physical safeguards designed and intended to protect personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. Personal information collected by RONA, whether in electronic form or paper form, is protected by security measures appropriate to the sensitivity of the information. The personal information you provide RONA is stored on computer systems located in controlled facilities which have limited access. RONA requires that highly confidential information be transmitted through the use of secure methods.
RONA evaluates its equipment and security procedures regularly and modifies them as necessary. Despite these safeguards, due to inherent uncertainty in the use of the Internet and information systems and the potential for unlawful attacks by third parties, RONA cannot guarantee that the use of our systems, websites, or applications will be completely safe or secure.
RONA may process and store your personal information at a RONA facility or a facility of an affiliate of RONA in the United States of America, India, or any other country in which it maintains its facilities. In addition, some of your information may be used, processed and/or stored by a RONA service provider, agent or supplier which may be located outside of Canada. Information located outside of Canada may be subject to access by law enforcement or other governmental agencies in those countries which such information is situated pursuant to lawful orders or legal process. While your personal information may be subject to the laws of those jurisdictions, RONA policies require that personal information used, processed and/or stored outside of Canada are always subject to protections comparable to those required under the applicable laws of Canada and will not be disclosed to third parties except with consent or as set out in this Privacy Statement. If you would like to obtain access to written information about RONA policies and practices with respect to its service providers located outside of Canada or otherwise have any questions regarding these service providers, please contact RONA Privacy Officer at the How to Contact Us address below.
Please do not transmit sensitive personal information (such as credit card numbers) using your personal e-mail account. E-mail providers typically do not automatically encrypt outgoing messages. If you receive an e-mail or telemarketing call from someone claiming to represent RONA and asking for your personal information, DO NOT RESPOND. If RONA needs information from you on-line, RONA will provide you with a secure online form. If RONA needs information from you verbally, RONA will request the information only when you initiate the call to RONA or if you are speaking with a RONA employee in-person.
A. How RONA Obtains Your Consent
You provide your consent to the collection, use and disclosure of personal information in accordance with this Privacy Statement when you voluntarily provide the requested information. You provide your implied consent to the use of the kinds of automatic data collection methods described in this Privacy Statement by your continued use of the RONA website or applications. You provide your implied consent to the collection, use and disclosure of personal information with respect to video surveillance by entering RONA stores or other facilities. You provide your implied consent to the collection, use and disclosure of personal information with respect to telephone calls with RONA by engaging in such calls. If RONA obtains information from third parties other than public sources, RONA requires those third parties to confirm that they have your consent to disclose your personal information for use by RONA.
B. Withdrawal of Consent
You have the right to withdraw your consent to certain uses and disclosures of your personal information. However, there are certain circumstances where you must provide your consent to the collection, use and disclosure of your personal information based on the action you are taking. For example, in the event you walk into one of our stores, you may not withdraw your consent to capture your image on our surveillance systems. In the event you are permitted to withdraw your consent and choose to do so by providing use notice thereof as contemplated below, RONA will take reasonable steps to destroy or delete the applicable personal information, but please note that residual personal information may remain in archived records or other historical records. In addition, RONA is not permitted to destroy business or accounting records of transactions that it is required to keep to comply with statutory or other legal obligations, assert its legal rights, or comply with its obligations to the provider of the debit or credit card you used. However, RONA will not use your personal information subject to the foregoing for other commercial purposes once you withdraw your consent. In some circumstances, the withdrawal of consent to certain uses or disclosures of personal information may mean that RONA is no longer able to provide certain products or services to you or RONA may be unable to perform certain transactions for you.
You may make a written request to RONA Privacy Officer at the How to Contact Us address below. When submitting a withdrawal of consent, you will be asked to provide suitable identification or to otherwise identify yourself.
C. Individual Access to and Correction of Personal Information
RONA strives to keep accurate information by using technology and management processes and policies. Upon receipt of a written request, RONA will provide individuals with reasonable access to the personal information they provided to RONA as well as the ability to correct the information, if necessary. To protect your privacy and security, RONA will also take reasonable steps to verify your identity before releasing any information to the requesting party and before any corrections will be made. RONA reserves the right to request appropriate proof of the requested corrections.
If you have chosen to become a registered user on any RONA website and would like to view, change, update or delete any of your registration information, log in and click Your Account at the top of the screen. You will be taken to a page where you can access your information so that you can edit it. Otherwise, to obtain access to the personal information you’ve provided to RONA, you may submit a written request to RONA Privacy Officer at the How to Contact Us address below.
Other Important Considerations
A. Do Not Track
We do not collect personally identifiable information about users’ online activities over time and across third-party websites and we do not process or respond to “Do Not Track” signals from your browser or other mechanisms that enable consumer choice regarding the collection of personal information about one’s online activities over time and across third-party websites or online services.
As described in the Interest-Based Advertising section below, however, we do participate in online advertising networks administered by third parties, and we may share information about activities on our websites with those networks, which may track your online activities over time and across third-party websites.
B. Interest-Based Advertising
RONA may collect data about your activities on our websites for use in providing advertising tailored to your individual interests, and we may share information about activities on our websites with advertising networks administered by third parties. These ad networks track your online activities over time and across websites by collecting information through automated means, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our websites, such as the pages you have viewed. This collection and ad targeting takes place both on our websites and on third-party websites that participate in the ad network, such as sites that feature advertisements delivered by the ad network. As a result, you may see certain ads on other websites based on prior activity on our websites, and vice versa.
The Digital Advertising Alliance of Canada (DAAC) has created guidance for online advertisers and provided a mechanism for such advertisers to comply with users’ choices regarding interest-based ads. To learn more about ad networks, including how to opt out of interest-based ads, click here.
RONA websites and applications may include social media features (for example, a Facebook “Like” button). These features are connected to third-parties and may allow such third parties to collect certain information, such as your IP address and which pages you visit on our websites. These social media features are not operated by RONA. Your interactions with these features are governed by the privacy policies of the company providing the features.
Generally, RONA does not knowingly collect personal information from persons under the age of 18. Nor does RONA target its websites to children under 13. RONA encourages parents and guardians to take an active role in their children’s online activities and interests. If RONA determines that personal information has been provided by a person under the age of 18, RONA will delete that information as soon as practical unless such deletion is inappropriate given the context (for example, employment applications, loss prevention, fraud and other investigative purposes). If you become aware that such personal information has been provided by a person under the age of 18, please submit a written request to RONA Privacy Officer at the How to Contact Us address below so the information can be deleted.
F. Changes to this Privacy Statement
If RONA changes this Privacy Statement, RONA will post the revised statement in its entirety on the www.rona.ca, www.reno-depot.com, and other applicable websites with an updated revision date. If RONA makes material changes to the way it collects or uses personal information, RONA may also notify you by other means such as sending an e-mail or posting a notice on the home page or in the RONA stores.
G. How to Contact Us
RONA values your opinions. If you have a privacy inquiry, compliment or complaint, you may contact the Store Manager of the store you visited. You may also direct your inquiry, compliment or complaint to RONA Privacy Officer at firstname.lastname@example.org, or by submitting a written request to:
Attn: RONA Privacy Officer
220 Chemin du Tremblay
Boucherville, Quebec J4B 8H7