Looniesaver, by its General Partner, Looniesaver GP Inc. (hereinafter “Looniesaver”) is committed to safeguarding the personal information entrusted to us by our Franchisees and Retail Clients. We manage personal information in accordance with Ontario’s Personal Information Protection Act and other applicable laws. This policy outlines the principles and practices we follow in protecting the personal information of our Franchisees and of Retail Clients.
For purposes of this policy, “Franchisee” also includes prospective and former Franchisees, “Retail Client” means customers and third parties dealing with the Store locations and business of those Franchisees, as well as Retail Clients of Stores that may be owned by Looniesaver subsidiaries that operate retail Stores, and Retail Clients who use BookMe offered by Looniesaver for appointments at all retail Stores, “Store” includes a salon or combined salon and beauty supply retail business and “BookMe” is the system with which Retail Clients may book appointments online and through mobile devices.
This policy applies to Looniesaver and, except to the extent of the foregoing paragraph, its subsidiaries including, without limitation, Looniesaver Assetco Ltd., Looniesaver Salon Limited and any related, affiliated or subsidiary entity of Looniesaver or any of the aforementioned corporate entities (collectively called “Looniesaver”). This policy also applies to any person providing services on our behalf.
Copies of this policy are available to any Franchisee or Retail Client on request, and on our web site at www.onlinelooniesaver.com.
WHAT IS PERSONAL INFORMATION?
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, educational history, etc., or video images of an individual.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect only the personal information reasonable for the purposes of providing services to Franchisees and Retail Clients, and for the purposes of managing Looniesaver and its franchise business.
From Franchisees we collect personal information needed to:
- evaluate suitability of applicants as a Looniesaver Franchisee
- enter into franchise agreements and contracts
- deliver requested products and services
- provide information on warranties for products and services
- notify Franchisees of upcoming events of interest
- initiate, administer, and terminate our Franchisee – franchisor relationships
- ensure Franchisee compliance with our requirements
- meet regulatory requirements
- manage day to day administrative matters
- provide information on future or additional business opportunities
- provide advice with respect to product placement, layout and merchandising
We also collect personal information so that Looniesaver may manage its franchise business, including, without limitation, to improve its franchise business and brand, monitor Franchisee compliance (such as by ensuring there is no diversion), to manage Looniesaver liability with respect to safety and security, and to ensure compliance with its own obligations to its own suppliers.
for the purpose of responding to or contacting Retail Clients with respect to their interaction at a Store or with a Franchisee.
for the purpose of providing Retail Clients the ability to make appointments through BookMe.
in the normal course of our day to day business operations to the extent that subsidiaries of Looniesaver own and operate Stores.
BookMe is operated by a third party service provider. To use BookMe Retail Clients must enter certain personal information into the service. Such personal information is collected, used and disclosed solely for the purpose of operating BookMe and for assessing the frequency of use of the BookMe service by Retail Clients, so we may continue to improve the BookMe service.
We ask for consent to collect, use or disclose Franchisee and Retail Client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may also rely on providing adequate notice, or assume your consent in cases where you volunteer information for an obvious purpose. With respect to personal information of Retail Clients collected by a Franchisee, we rely on the consent obtained by our Franchisees in accessing that personal information.
In cases where we collected personal information before January 1, 2004, we assume your consent to our use and, where applicable, disclosure for the purpose for which the information was collected.
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask you to provide your consent in writing by signing a consent form or by checking a box on a form, electronically by clicking a button, or orally. We will not use your personal information for marketing purposes without your consent, unless otherwise allowed by law.
As Retail Client or Franchisee you may withdraw your consent to the use and disclosure of your personal information at any time, unless the personal information is necessary for us to fulfill our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
We may collect, use or disclose Retail Client or Franchisee personal information without consent only as authorized by law. For example, we might not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.
HOW DO WE USE AND DISCLOSE PERSONAL INFORMATION?
We use and disclose Retail Client and Franchisee personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may use Retail Client and Franchisee contact information to deliver goods and to provide BookMe. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary.
In addition Looniesaver may access a Franchisee’s video surveillance footage with for purposes of monitoring licensed sales, security and loss prevention, and management of Looniesaver’ liability, and upon request by a Looniesaver Franchisee, in order to provide advice to that Franchisee with respect to product placement, layout and merchandising.
Such footage may capture Retail Clients and employees of Looniesaver’s Franchisees, and where a Looniesaver location is owned by a subsidiary of Looniesaver, Retail Clients and employees of that Store.
If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.
HOW DO WE SAFEGUARD PERSONAL INFORMATION?
We make every reasonable effort to ensure that Franchisee and Retail Client information is accurate and complete. We rely on our Franchisees and Retail Clients to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect client personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. Specific mechanisms include limiting disclosure of personal information to Looniesaver employees that reasonably require it to carry out their functions, physical locks and storage security and implementation of web passwords and IT security systems. When we collect video footage of our Franchisee’s locations, we limit access to certain senior officers of Looniesaver.
We also use appropriate security measures when destroying Retail Client and Franchisee personal information, including shredding paper records and to the extent reasonably possible, permanently deleting electronic records.
We retain Franchisee and Retail Client personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.
BookMe is provided by a third party who is contractually obligated to protect the personal information of Retail Clients collected through BookMe. The third party may store personal information of Retail Clients on servers located outside of Canada. Looniesaver and the third party service provider for BookMe use appropriate security measures to protect personal information collected through BookMe, however it is important to remember that there are inherent risks associated with providing personal information online or through SMS or other mobile applications.
ACCESS TO RECORDS CONTAINING PERSONAL INFORMATION
Franchisees and Retail Clients have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may make a request for access to your personal information by writing to
Legal & Development
8-50 Bennett St Carleton Place, ON K7C 4J9
Or by sending an email to email@example.com
You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. For personal information collected before January 2004, if we do not have a record of disclosures, we will provide information about any disclosure of your information that is likely to have occurred.
You may also request a correction of an error or omission in your personal information.
We will respond to your request within 30 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.
Your Internet browser has a feature called “cookies,” which stores small amounts of data on your computer about your visit to our website and permits the site to recognize future visits using that computer. Cookies tell us nothing about who you are unless you specifically give us personal information.
QUESTIONS AND COMPLAINTS
If you have a question or concern about any collection, use or disclosure of personal information by Looniesaver, or about a request for access to your own personal information, please contact in the first instance, at the following:
Legal & Development
8-50 Bennett St Carleton Place, ON K7C 4J9
If you are not satisfied with the response you receive, you may also contact the Information and Privacy Commissioner of Ontario:
Office of the Information and Privacy Commissioner of Ontario
Suite 2460, 801 – 6 Avenue, SW
Calgary, Ontario T2P 3W2
Phone: (403) 297-2728
Toll Free: 1-888-878-4044
Web site: www.oipc.ab.ca