SUMMARY

We may collect the following Personal Information (learn more under section 2 of the full Policy below):

When you complete our Contact Form on our website:

• name, email address, company;
• subject matter of your inquiry;
• other information that you may choose to share with us in your message.

When you complete a transaction on our website:

• payment information, including your credit card number or debit card number, billing address and transaction history (we do not retain the full payment details, which are retained by our payment providers Shopify Payments [See Shopify's Privacy Policy]) and/or PayPal [see PayPal's Privacy Policy]);
• shipping address;
• your role in your organization in order to better understand our target audience and to improve the provision of our products and services.

When you use our website:

• The following usage information that may be collected automatically through the use of analytics tools (Google Analytics [See Google’s Privacy Policy], Shopify Analytics [See Shopify's Privacy Policy] and Facebook Pixel [see Facebook's Data Policy]) in order to better understand our target audience and to improve the quality of our products, services and website:
• information about your browser, network and device;
• information about the webpages you visited prior to coming to our website;
• network location and IP address.

We may use your Personal Information for the following purposes (learn more under section 5 of the full Policy below):

• to provide you with our products or services, and the use of our website;
• to complete transactions and process payment;
• to respond to your inquiries;
• to provide a better user experience with respect to the use of our website;
• to better understand our target audience and to continue improving the quality of our products, services and website;
• to communicate with you about our products and services, including updates or newsletters, or to deliver content that may be of interest to you;
• to ensure that our website remains functioning and secure;
• to investigate, prevent or act on any illegal activities or violations of our Terms of Service;
• to screen our orders for potential risk or fraud.

We may share your Personal Information with the following parties (learn more under section 6 of the full Policy below):

1. individuals or organizations who are our advisers or consultants;
2. our payment providers Shopify Payments [See Shopify's Privacy Policy]) and/or PayPal [see PayPal's Privacy Policy]) for the purposes of completing transactions with respect to our products and services;
3. our printing service provider, UPS store 404 and/or UPS store 398 [See UPS's Privacy Policy];
4. the following advertising, marketing and analytics service providers: Google Ads; Google Analytics [See Google’s Privacy Policy]; Shopify Analytics [See Shopify's Privacy Policy]; and Facebook Pixel [see Facebook's Data Policy];
5. other service providers, including individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading of our computer systems.

You have the following choices (learn more under section 12 of the full Policy below):

Depending on the products, services or your use of our website, your choices may include the following:

• Cookies Settings and Preferences. You may disable cookies and other tracking technologies through the settings in your browser. While doing so may negatively affect your experience with the use of our website, it will not prevent us from transacting with you.

• E-mail Settings and Preferences. You may sign up for our mailing lists in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive marketing e-mails from us, you may choose to unsubscribe at any time by clicking on the “unsubscribe” link in our emails or by contacting us at jsharpe@sharpeaero.com.

• Opt-Outs. You may contact us (see section 14 of the full Policy below) to opt out of the use or sharing of your personal information, including for marketing purposes, and/or the provision of your personal information to our business partners for such purposes.

• Analytics Tools. You may opt out of the use of your personal information for analytics purposes as follows: [Opt out of Google Analytics], [Opt out of Facebook targeted advertising] or, if you have expressly “opted in” to Shopify Analytics using the cookie banner function, you can later opt out by disabling cookies in your web browser by following the instructions available under section 4 of the full Policy below.

In case of a breach of security safeguards, we will (learn more under section 10 of the full Policy below):

• determine whether the breach creates a real risk of significant harm to you, including physical, financial or reputational harm;
• notify you, the Office of the Privacy Commissioner of Canada and any provincial Information and Privacy Commissioners, as appropriate;
• notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach; and
• keep a record of the breach in accordance with our legal obligations.

How to contact us (learn more under section 14 of the full Policy below):

For more information about this Policy, our privacy practices or to obtain access to or correction of your Personal Information, please contact our Privacy Officer at jsharpe@sharpeaero.com.

PRIVACY POLICY

Privacy Principles

SharpeAero complies with the following principles set out in Schedule I to PIPEDA:

Principle 4.1 (Accountability) – An organization is responsible for personal information under its control and must designate an individual responsible for compliance with PIPEDA;

Principle 4.2 (Identifying Purposes) – An organization must specify why it is collecting personal information, and such purposes must be identified at or before the information is collected;

Principle 4.3 (Consent) – An organization must obtain an individual’s consent for the collection of personal information and subsequent use and disclosure;

Principle 4.4 (Limiting Collection) – An organization must limit the collection of information to that which is necessary for the identified purposes;

Principle 4.5 (Limiting Use, Disclosure, and Retention) – An organization must not use or disclose personal information for a purpose other than for which it was collected, except with the consent of the individual or where required or permitted by law;

Principle 4.6 (Accuracy) – An organization must ensure that personal information it maintains is accurate, complete, and up to date;

Principle 4.7 (Safeguards) – An organization must take appropriate safeguards to protect personal information;

Principle 4.8 (Openness) – An organization must be open about its policies and practices;

Principle 4.9 (Individual Access) – An organization must provide individuals with a right of access to their personal information, subject to certain restrictions as set out in PIPEDA; and

Principle 4.10 (Challenging Compliance) – An organization must advise individuals of its complaint procedures.

1. What is Personal Information?

"Personal Information" means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information. “Personal Information” may or may not include business contact information, depending on the jurisdiction.   

Anonymized data
This Policy does not cover anonymized aggregated data from which the identity of an individual cannot be determined. SharpeAero retains the right to use business contact information and aggregated data in any way that it determines appropriate.

2. What Personal Information do we collect?

We may collect the following types of personal information when you complete the Contact Form on our website:

• name, email address, company;
• subject matter of your inquiry;
• information that you may choose to share with us in your message. 

We may collect the following types of personal information when you complete a transaction with us:

• payment information: credit card number, billing address and transaction history; we collect payments by debit and credit cards, as well as Apple Pay, through our payment providers Shopify Payments [See Shopify's Privacy Policy]) and/or PayPal [see PayPal's Privacy Policy]. We do not have access to credit card or debit card information other than the last 4 digits of your credit card number.
• shipping address;
• your role in your organization in order to better understand our target audience and to improve the provision of our products and services.

Customer Account
You can create a customer account during checkout in order to make ordering in the future faster and easier. We will retain your name, shipping and billing addresses, email address, previous order details, and payment method. If you choose the option to remember your card information, the full credit card details will be saved by our payment providers Shopify Payments and/or PayPal. We will only retain the last 4 digits of your card number. 

Automatic Collection
Our website is configured to automatically collect, through the use of analytics tools (Google Analytics [See Google’s Privacy Policy], Shopify Analytics [See Shopify's Privacy Policy] and Facebook Pixel [see Facebook's Data Policy]), the following types of usage information in order to better understand our target audience and to improve the quality of our products, services and website:

• information about your browser, network and device;
• information about the webpages you visited prior to coming to our website;
• network location and IP address.

3. How do we collect your Personal Information?

SharpeAero only collects Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing our products, services or website. We use only fair and lawful methods to collect Personal Information.

(i) Consent
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and disclosure of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the information for a new or different purpose where the individual concerned has not already consented to such a use of their personal information. 

(ii) Withdrawing your consent
In most cases and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice. Consent cannot be withdrawn retroactively. It should be noted that in certain circumstances, our products or services can only be offered if you provide us with your Personal Information. Consequently, if you choose not provide us with the required Personal Information, we may not be able to offer you these products or services. We will inform you of the consequences of the withdrawal of consent.

4. Cookies and tracking technologies

We use cookies (data files placed on your device) on our website to collect usage information when you visit our website. We may place cookies or similar files on your device for security purposes, to facilitate site navigation, or to integrate the website with the services provided by our service providers.

Disabling cookies: To learn how you may be able to reduce the number of cookies you receive from us, or disable cookies that have already been installed in your browser's cookie folder, please refer to your browser's help menu or other instructions related to your browser. You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers. Note that while disabling cookies may negatively affect your user experience on our websites, it will not prevent us from transacting with you.

Do not track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. 

5. How do we use your Personal Information? 

We use the information we collect for the following purposes:

• to provide you with our products, services and website;
• to complete transactions and process payment;
• to respond to your inquiries;
• to provide a better user experience with respect to the use of our website;
• to better understand our target audience and to continue improving the quality of our products, services and website;
• to communicate with you about our products and services, including updates or newsletters, or to deliver content that may be of interest to you;
• to ensure that our website remains functioning and secure;
• to investigate, prevent or act on any illegal activities or violations of our Terms of Service;
• to screen our orders for potential risk or fraud.

Our use of Personal Information is limited to the purposes described in this Policy. We do not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information we have obtained.

6. How do we share your Personal Information?

We may share your Personal Information with the following third parties:

1. individuals or organizations who are our advisers or consultants;
2. our payment providers, Shopify Payments [See Shopify's Privacy Policy] and/or PayPal [see PayPal's Privacy Policy] for the purpose of completing transactions with respect to our products and services;
3. our printing service providers, UPS store 404 and/or UPS store 398 [See UPS's Privacy Policy];
4. the following advertising and marketing service providers: Google Ads; Google Analytics [See Google’s Privacy Policy]; Shopify Analytics [See Shopify's Privacy Policy]; and Facebook Pixel [see Facebook's Data Policy]
5. other service providers, including individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading of our computer systems.

(i) Third Party Service Providers
We may contract with third party service providers to provide support services required for the provision of our products, services or website. When we transfer Personal Information to service providers or contractors that perform services on its behalf, we will require those third parties to use such information solely for the purposes of providing services to us or our users, and to have appropriate safeguards for the protection of that Personal Information.

(ii) Where Disclosure can be made without consent
Please note that there are circumstances where the use and/or disclosure of Personal Information may be required or permitted without consent.  Such circumstances may include:

1. Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;

2. Where SharpeAero believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;

3. Where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain;

4. Where the information is public as permitted by law;

5. Where it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or

6. Where it is necessary for the purpose of a prospective business transaction if the information is necessary to determine whether to proceed with the transaction or to complete the transaction, or a completed business transaction where the information is necessary to carry on the activity that was the object of the transaction. A “business transaction” includes:

• the purchase, sale or other acquisition or disposition of an organization or a part of an organization, or any of its assets;
• the merger or amalgamation of two or more organizations;
• the making of a loan or provision of other financing to an organization or a part of an organization;
• the creating of a charge on, or the taking of a security interest in or a security on, any assets or securities of an organization;
• the lease or licensing of any of an organization’s assets; and
• any other prescribed arrangement between two or more organizations to conduct a business activity.

Where required or permitted to disclose information without consent, we will not disclose more information than is required.

7. How long do we retain your Personal Information?

We keep your Personal Information only as long as it is required for the reasons it was collected.  The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. As such, we may keep your account information after the termination of your account.

When your Personal Information is no longer required for the purposes for which it was collected, we will destroy, delete, erase or convert it into an anonymous form.

8. Where do we store your Personal Information? 

(i) Cross Border Transfer of Information 
SharpeAero may transfer personal information to a service provider which is located outside of Canada where privacy laws may offer different levels of protection from those in Canada. Your Personal Information may also be subject to access by and disclosure to law enforcement agencies under the applicable foreign legislation.

9. How do we protect your Personal Information? 

SharpeAero endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information. We further protect Personal Information by restricting access to it to those employees that require access to the information in order to provide our products, services or website.

10. What do we do in case of a privacy or security breach?

A “breach of security safeguards” is defined as the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards. In case of a breach of security safeguards involving your Personal Information under our control, we will notify you and the Privacy Commissioner of Canada, and any provincial Information and Privacy Commissioner, as appropriate, if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you, including physical, financial or reputational harm. We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach. We will keep a record of all breaches in accordance with our legal obligations.

11. How can you access or correct any inaccuracies in your Personal Information?

SharpeAero endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the Personal Information and, if necessary, use its best efforts to inform third party service providers or contractors which were provided with inaccurate information so that those third parties may also correct their records.

SharpeAero permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.

14. Resolving your Privacy Concerns

In the event of questions about: (i) access to your Personal Information;  (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact our Privacy Officer by sending an e-mail to jsharpe@sharpeaero.com.

We will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue. If we are unable to resolve your concerns to your satisfaction you may contact the Privacy Commissioner of Canada by writing to:

Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, Quebec
K1A 1H3 

https://www.priv.gc.ca/en/contact-the-opc/

15. Changes to this Privacy Policy

We will update this policy from time to time if our practices change or if the law requires changes to it. We will post any Privacy Policy changes on this page, and, if the changes are significant, we will provide a more prominent notice and a summary of the relevant changes at the top of the page. You should review this policy regularly for changes, and can easily see if changes have been made by checking the Effective Date below. If you do not agree to the terms of this Privacy Policy or any other SharpeAero policy, agreement, or disclaimer, you should exit the site and cease use of all SharpeAero services immediately. Your continued use of the website and services following the posting of any changes to this Policy means you agree to be bound by the terms of this Policy.

Effective Date: This Privacy Policy was last updated on September 6, 2020.