Personal Information Protection Policy
At Fashion 88, we are committed to providing our Vendors and their customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our, Vendors and their customers, protecting their personal information is one of our highest priorities.
While we have always respected our Vendors and their customers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our Vendors and their customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting Vendors and their customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our Vendors and their customers’ personal information and allowing our, Vendors and their customers to request access to, and correction of, their personal information.
Personal Information –means information about an identifiable individual, including name, age, home address and phone number, and browsing and purchasing activity including items purchases and prices paid on the fashion88.clothing site, and cookie information regarding previous browsing history as may be provided by affiliates. Personal information does not include contact information.
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Fashion 88 complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the Vendor and/or their customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect information from Vendor’s and their customers that is necessary to fulfill the following purposes:
• To verify identity;
• To identify vendor and customer preferences and trends;
• To open and manage an account;
• To facilitate Vendor customer transactions for requested products and services
• To contact our Vendor’s and their customers with new product information and sale opportunities;
To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain Vendor and Vendor customers’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided in writing through creating a vendor account or customer account, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the Vendor or their customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a Vendor or their customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for physical and electronic mail-outs for the marketing of new services or products, and the Vendor or their customer as may be applicable does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), Vendors and their customers can withhold or withdraw their consent for Fashion 88 to use their personal information in certain ways. A Vendor or their customers’ decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the Vendor or their customer as may be applicable in making the decision.
2.5 We may collect, use or disclose personal information without the Vendor or their customers’ knowledge or consent in the following limited circumstances:
• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual’s life, health, or personal security;
• When the personal information is available from a public source;
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose Vendor and Vendor customers’ personal information where necessary to fulfill the purposes identified at the time of collection, or for a purpose reasonably related to those purposes, such as:
• To conduct surveys in order to enhance the provision of our services;
• To contact our Vendors and or their customers directly about products and services that may be of interest;
• To comply with legal requests and court orders
3.2 We will not use or disclose Vendor and their customers’ personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell Vendor and their customers’ lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client, customer, member personal information to make a decision that directly affects the client, customer, member, we will retain that personal information for at least one year so that the client, customer, member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, customer, member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that Vendors and their customers personal information is accurate and complete where it may be used to make a decision about the Vendor or their customer or disclosed to another organization.
5.2 Vendors and their customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing addressed to the Privacy Officer and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 We will use appropriate security measures when destroying Vendor and their customers as may be applicable, personal information such as deleting electronically stored information.
6.3 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Vendor’s and their Customers Access to Personal Information
7.1 Vendors and their customers have a right to access their personal information, subject to limited exceptions authorized by law.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought and forwarded to the Privacy Officer.
7.3 Upon request, we will also tell Vendors and their customers how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the Vendor and their customer as may be applicable of the cost and request further direction from them on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the requestor in writing, providing the reasons for refusal and the recourse available to them.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Fashion 88’s compliance with this policy and the Personal Information Protection Act.
8.2 Vendors and their customers as may be applicable should direct any complaints, concerns or questions regarding Fashion 88’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the complainant may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Fashion 88