Privacy Policy

INTRODUCTION

The following is the privacy policy (the “Privacy Policy”) of 公司 International Trading Ltd. (together “公司”, “we”, “us” or “our”). 公司 recognizes the importance of your right to privacy, and we are committed to safeguarding Personal Information (as defined below) that 公司 collects, uses, and discloses from and about users of this site (the “Site”) as well as our apps, other websites (such as https://thewisecents.com), or offline services, in each case that link to or expressly reference this Privacy Policy (collectively, the “Sites/Services”).

This Privacy Policy sets out the way we use your Personal Information: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled. We advise you to read this Privacy Policy in its entirety, including the jurisdiction-specific provisions in this Privacy Policy, which will apply to users in certain jurisdictions.

This Privacy Policy is designed to be reasonably accessible to people with disabilities. If you experience any difficulties accessing the information in this Privacy Policy, please email us at [email protected].

If you are located in the UK, Switzerland, or EEA, our collection, use, and disclosure of information about you is governed by the privacy policy available here and not this Privacy Policy.

If you are located in the US, our collection, use, and disclosure of information about you is governed by the privacy policy available here and not this Privacy Policy. Please note that the “Notice at Collection; Categories of Personal Information We Collect and Use” section in our US Privacy Policy, which describes our collection and use of information practices through the Sites/Services, also serves as our Notice at Collection for California residents for purposes of the California Consumer Privacy Act (“CCPA”).

NOTICE AT COLLECTION; CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND USE

ADVERTISING, MARKETING, AND ANALYTICS ACTIVITIES

RETENTION OF PERSONAL INFORMATION

SOURCES OF PERSONAL INFORMATION

DISCLOSURE OF PERSONAL INFORMATION

DATA TRANSFERS

COOKIES, WEB BEACONS, TAGS AND OTHER SIMILAR TECHNOLOGIES

YOUR RIGHTS AND CHOICES

A. PRIVACY RIGHTS

B. COOKIES AND INTEREST-BASED ADVERTISING

C. UNSOLICITED COMMUNICATIONS

THIRD PARTY LINKS

PRIVACY GOVERNANCE AND SECURITY

CHILDREN’S PRIVACY

CHANGES TO THIS PRIVACY POLICY

HOW TO CONTACT US

NOTICE AT COLLECTION; CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND USE

We collect certain types of Personal Information from or about you throughout our interaction with you and from other sources.

“Personal Information” is any information:

that identifies or can be used to identify you or your household;
that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your or household;
that can be used to authenticate you or provide access to an account;

Personal Information does not include aggregated, de-identified, or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you. We will maintain and use de-identified information in de-identified form and will not attempt to re-identify such information, except to make sure the information is truly de-identified.

Over at least the last 12 months, we have collected, used, and disclosed the categories of Personal Information listed in the table below for the purposes and activities we have listed in the table below. In addition, we sell and share the following categories of Personal Information for cross-context behavioral and targeted advertising: personal identifiers, demographic information, commercial information, device, internet and network activity information, online identifiers, general location information, and inferences drawn from the above categories.

Personal Information may also be processed if it is necessary:

on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claim;
to address or prevent a policy or terms violation;
to enforce our rights;
to enforce our agreements;
to protect against unauthorized access to our systems or other inappropriate use of our Sites/Services; and
to provide you with a service or experience at your request.

We will not delete Personal Information if relevant to an investigation or dispute. It will continue to be stored until those issues are fully resolved.

We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our products to you based on fraud detection and creditworthiness checks. This will be informed by verification of Personal Information (including by vendors engaged by us). Depending on the outcome of these checks, a decision will be reached automatically as to whether we are able to provide products to you.

Where we need to collect your Personal Information under the terms of a contract, we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide our products to you).

ADVERTISING, MARKETING, AND ANALYTICS ACTIVITIES

Email marketing communications – our email marketing will include press releases and information about us, our website, our products and services, any events we may hold and the offers and promotions we offer from time to time. Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you.

Online behavioural advertising – we and our third party partners may use your personal data that we have collected and other data that is collected through your interactions with third party websites and services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the “social media retargeting” section below). By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our website or which you otherwise might be interested in based on your browsing habits, although our third- party partners may use the data that is collected to show personalised ads for products and services offered by third parties.

These vendors may collect information about your visits to our website, and your interactions with our products and services. Such vendors may place and access their own cookies, tags, web beacons or similar technologies on your computer or device used to access the website to serve you ads or other content personalized to your interests (“Interest-based Advertising”). In addition to the information about your visits to our website, these vendors may also use the information about your visits to other websites to target advertisements for products and services available from 公司.

As described in more detail in the “Cookies and Interest-Based Advertising” section below, you may be able to set your browser to reject cookies later. In that case, you may still receive online advertising, but it may be less personalized.

Social media retargeting – If we advertise to you on social media and other platforms we share your email address (usually in an encrypted or ‘hashed’ form) with third-party ad partners or providers of social media platforms and other services, such as Facebook and Google and other similar platforms (“Social Platforms”), so that the third party providers can try to “match” your data with the data of their registered users of their Social Platforms. This is done by us providing a list of hashed email addresses to Social Platforms or incorporating a pixel from Social Platforms into our own Sites/Services, and the Social Platforms matching common factors between our data and their data collected via cookies or pixels. For instance, we may incorporate the Facebook pixel on our Sites/Services and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Where there is a successful match, we will display our advertising to you when you use the relevant Social Platform (e.g., on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant service. Some of the advertising that you see may be personalised to you. For more information about the cookies used by these Social Platforms and our partners, please see the Cookies section.

If we advertise to other people who share similar interests and characteristics to you, we will also provide your personal data to Social Platforms. If you are a user of those Social Platforms, we may ask the Social Platforms to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other registered users. This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” you.

Please note that such activity is also subject to the privacy choices you have elected to make on such third-party services.

The relevant Social Platform act as our service provided and in other contexts may also be a controller in respect of the personal data that is collected via your use of our social media pages and may independently use that personal data for additional purposes. For details of how the relevant Social Platform uses your personal data as well as how to request a deletion of personal information collected by these Social Platforms, please see the privacy policy of the relevant Social Platform.

In addition, as described in more detail in the “Cookies and Interest-Based Advertising” section below, you may be able to set your browser to reject cookies later. In that case, you may still receive online advertising, but it may be less personalized.

Measurement – We will also use other tools provided by such Social Platforms and other advertising partners for the purposes of serving you with and measuring advertisements in different ways, including, search management platforms for managing campaigns, analytics services to understand how you interact with our content (including on the relevant Social Platforms), tools which allow us to understand whether you have purchased a product based on advertisements served to you on a Social Platform or otherwise and tools to serve you with our ads when you search on a Social Platform or other third party sites. Such activities may involve sharing your transaction data with the Social Platforms and other advertising partners, in addition to your hashed email address. For more information about the advertising partners and Social Platforms we use, please see our Cookies section.

RETENTION OF PERSONAL INFORMATION

公司 maintains a Data Retention Policy that is accessible to all employees. As set out in this policy, we will keep Personal Information for as long as it is reasonably necessary considering the purposes for which Personal Information has been collected or as required by law. It will depend on factors such as whether you have any outstanding purchases or an account with us or have interacted with recent offers.

For further information on how long we will keep Personal Information, please contact our privacy officer at [email protected].

SOURCES OF PERSONAL INFORMATION

We collect Personal Information in the following ways:

Directly From You (either offline or through the Sites/Services). For example, when you:

Register for a 公司 account
Make reservations for a 公司 event
Sign up to receive promotional communications
Submit a request to or contact our customer service team
Apply for a job through our Sites/Services

Automatically through Cookies and Similar Technologies. For example, when you:

Visit and navigate our Sites/Services on any device
Click on sponsored links or third-party advertisements

We may also use cookies and similar technologies owned and operated by other entities to collect Personal Information about you over time and across different websites, apps, and devices. For more information about our use of cookies and other similar technologies, please refer to the section called “Cookies, Web Beacons, Tags and Other Similar Technologies” below.

From Service Providers and Contractors. For example, we work with service providers and contractors who collect Personal Information on our behalf in order to:

Run and manage our Sites/Services
Offer and improve products and services
Provide IT development and support
Host and carry out marketing and business studies and marketing campaigns
Verify your information
Authenticate payments and process orders and payments
Provide fulfilment services
Provide delivery services
Provide customer service

From Other Entities. We may receive Personal Information about you from other sources. For example, this may include receiving Personal Information from:

Our business and website partners
Our marketing agencies, advertising technology vendors and networks, and analytics providers
Social media sites, including Facebook, YouTube, and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site. You can control what data you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how such social media sites treat Personal Information, please refer to their privacy policies and terms of use.
Companies that provide Personal Information to supplement what we already know about you, including data aggregators and trade publications. Certain parties might link your name or email address to other information they have collected. That might include past purchases or reservations for events made offline or online. It might also include Device, Internet and Network Activity Information, Online Identifiers (IP Address, cookie IDs and Device IDs)

From Other Users. For example, we also collect information from other users, such as:

A spouse who contacts us on your behalf
A friend who provides us with your information in order to invite you to events you may be interested in

Publicly Available Sources. For example, we collect:

Information in the public domain
Data available in open government databases to help us with fraud monitoring and prevention, compliance with applicable law and regulations, reviewing and processing your employment application, and other information
Information as otherwise permitted by law

By Combining Personal Information. For example, we may:

Combine Personal Information that we collect offline with Personal Information we collect through our Sites/Services
Combine Personal Information we collect about you from the different devices you use to access our Sites/Services
Combine Personal Information we get from third parties with Personal Information we already have about you.

DISCLOSURE OF PERSONAL INFORMATION

During at least the past 12 months, we have disclosed certain categories of Personal Information outlined above with the following categories of entities:

We share all categories of Personal Information outlined above with other members of our group of companies so that we can provide the best service across our group. They are bound to keep and use Personal Information in accordance with this Privacy Policy.
We also share all categories of Personal Information outlined above with contractors, service providers and advisors that help with our business operations (for example, order fulfilment, order delivery, cloud services, fraud prevention, customer services (including as necessary to interact with you through our live chat functionality), event operation and administration, payment processing and marketing) and they may process Personal Information for us. They are required to meet our standards on processing and security of Personal Information. The information we provide them with, including Personal Information, will only be provided in connection with the performance of their function and as otherwise permitted by law.
We share personal identifiers, commercial information, device, internet and network activity information, online identifiers, general location information, and inferences drawn from these categories with third parties such as advertising and marketing providers, in order to serve advertisements on our behalf across the internet and for analytics related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising, marketing, and analytics, see the “Your Rights and Choices” section below.
We share employment-related information with external recruitment agencies and, in some instances, entities that undertake background checks on our behalf and other entities within our group of companies.
We share all categories of Personal Information outlined above with our business partners in connection with offering co-branded services, selling or distributing our services, and engaging in joint marketing activities.
We share all categories of Personal Information outlined above with prospective and actual purchasers, if we’re discussing or in the process of selling or transferring part or all of our business.
We share all categories of Personal Information outlined above where you have given us your consent to do so.
We share all categories of Personal Information outlined above with other parties when we are otherwise required or permitted by law, for example the Police, other government and regulatory agencies, and professional services firms who advise and assist us in relation to the lawful and effective management of our organization and in relation to any defense of a legal claim.

DATA TRANSFERS

Please be aware, we transfer information to our affiliates and subsidiaries and to other parties as described in this Privacy Policy, across international borders, and from your country or jurisdiction to other countries and jurisdictions around the world, including to the United States. As a result, your personal information may be transferred to, stored and/or processed in such other countries, including on servers located in such other countries.

If you are a Quebec resident, this means that your personal information may be transferred outside of Quebec. This also means your personal information may be transferred to or disclosed to service providers located outside of Quebec.

Your use of the Sites/Services or provision of any information to us therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in other regions with laws governing data collection and use that may differ from your region’s data protection laws.

COOKIES, WEB BEACONS, TAGS AND OTHER SIMILAR TECHNOLOGIES

Our Sites/Services use automatic data collection technology and services such as “cookies”, “web beacons”, “tags” and other similar technologies. A cookie is a small data file that is placed on the hard drive of your computer so that your computer will “remember” information when you visit a website. Web beacons and tags are small strings of code that are used in conjunction with a cookie and that allow us to record activity on our Sites/Services. A web beacon allows us to capture certain additional types of information about a visitor’s actions on a website, such as a visitor’s cookie number, device and browser information, the time, date, duration and number of page views, a description of the page where the web beacon is placed, and details about any items that were purchased.

When you use our Sites/Services, these technologies may record and collect Personal Information, such as information that identifies your computer, tracks your use of our website and collects certain information about you and your surfing habits. This information may include information that identifies your device, IP address, browser type and language preferences, and information about referring and exit pages and URLs, keywords, date and time, what sections of a website you visit, and other similar information concerning your use. This information is used for the purposes mentioned above and to help us serve you better by improving our website design, as well as our products, services, and promotions. We also use the technologies mentioned above to improve functionality of our Sites/Services and user experience.

Please note that any emails you receive from us may contain cookies to help us to see if recipients have opened an email and understand how recipients have interacted with it. Once you click on an email that contains a cookie, your contact information may subsequently be cross-referenced to the source email and/or the relevant cookie. If you have enabled images, cookies may be set on your computer or mobile device. Cookies will also be set if you click on any link within the email.

If you do not wish to accept cookies from any one of our emails, simply close the email before downloading any images or clicking on any links. You can also set your browser to restrict cookies or to reject them entirely. These settings will apply to all cookies whether included on websites or in emails.

Types of Cookies

We use “first party cookies” and “third party cookies” in connection with our products and services. First party cookies are cookies placed by us to collect information about you. Third party cookies are cookies placed by third party website operators. Information about you collected by those third-party cookies will be shared with the relevant third party. Please refer to the relevant third-party website operator’s privacy notice for more details about the information they collect and how they use it.

Our website uses the following types of cookies:

Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. Without these cookies we will not know when you have visited our site and will not be able to monitor its performance.
Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. Without these cookies then some or all of these services may not function properly.
Targeting Cookies: These cookies may be set through our site by our social platform and/or advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. Without these cookies you will experience less targeted advertising.

If you wish to block certain cookies, you can do so in the browser you are using. See the “Cookies and Interest-Based Advertising” section below for more information.

A. Privacy Rights

You may have certain rights in relation to your information including a right to access and rectification, to control the dissemination of personal information, or the right to data portability. Some of these rights will only apply in certain circumstances however, such as the right to request that we move your information to a person or body authorized by law to collect Your information. They will generally not be available if there are outstanding contracts between us, if we are required by law to keep the information, or if the information is relevant to a legal dispute.

If you would like to exercise, or discuss, any of these rights, please contact our privacy officer at [email protected].

Right to withdraw consent: You can remove consent, where you have provided it, at any time, as well as update any of your opt-in marketing preferences by contacting us at [email protected].
Right of access: You are entitled to obtain from us details concerning the processing of your personal information and to receive a copy of the personal information we process about you (including in electronic form). Additional copies may be subject to a reasonable administrative fee.
Right to rectification: You are entitled to have any incomplete and inaccurate personal information held by us rectified. If you have an account with our online store, you can log in and update your account information, including contact, billing and shipping information.
Right to data portability: In certain circumstances you can ask us to help you move your information to other persons or body authorized by law to collect your information.
Right to complain and appeal: In the event that your request is refused, we shall provide you with reasons for the refusal and indicate the provision of law on which the refusal is based, the remedies available to you, and the time limit for exercising those remedies. At your request, we will also assist you to understand our refusal. If you are Quebec resident and if you disagree with our refusal, you have the right to submit an application for the examination of the refusal to the Commission d’accès à l’information (the “Commission”) within thirty (30) days of our refusal to grant your request.

In response to verified requests pursuant to the rights above, we will disclose and deliver the required information to you no later than 30 days of receiving a verifiable consumer request. In Quebec, we may extend this time period by an additional 30-days by submitting, within the initial 30-day period, a request to the Commission.

Submission of Requests. You or your authorized representative may exercise these rights by submitting the request online here and specifying that you are making a “Privacy Rights Request” or by emailing us at [email protected]. In order to verify your request, we may require you (or your authorized representative) to provide your full name, your e-mail address, your mailing address and your phone number.

Authorized Agents. If you are an authorized agent seeking to submit a request on behalf of a consumer, you must make your request by emailing us [email protected].and put the words “Privacy Requests, Authorized Agents” in the subject field. You also need to attach to your email proof you have written authority to act for the consumer. You must also provide the full name, e-mail address, mailing address and phone number of the consumer you are representing so we can verify their identity. We will not be able to honor requests without sufficient documentation that you are authorized to represent the consumer.

Verification. We will take reasonable steps to verify your identity (or the identity and authority of your authorized representative) prior to responding to your requests.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, to process transactions, and to facilitate customer requests. Unless required by applicable law, employment-related Personal Information will not be included in the fulfillment of your requests.

Users Under 16. Note that the Sites/Services are not intended for users under the age of 16. We do not knowingly sell or share Personal Information from anyone under the age of 16. Please see our section titled “Children’s Privacy” above for more information.

B. Cookies and Interest-Based Advertising.

As noted above, this Privacy Policy applies to all Personal Information collected and processed by us using cookies, web beacons and tags on our Sites/Services.

You can easily change your “cookie settings” by changing the settings of your web browser (e.g., Internet Explorer, Google Chrome, Safari, etc.). For more information hereon, please refer to the ‘help’ section of your web browser and see below. When you turn off the use of cookies and similar technologies via your web browser settings, you may still visit our Sites/Services, but you may not be able to use some areas of the Sites/Services and the Sites/Services may not provide optimal functionality.

If you wish to block certain cookies, you can do so in the browser you are using by following the applicable link below:

C. Unsolicited Communications

公司 complies with applicable laws regarding unsolicited marketing messages (e.g., ‘spam’) and will not send you such messages in contravention of such laws. Our online store allows you to sign up and expressly consent to receiving electronic communications. We will ensure that each email includes an opt-out feature and instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. You may contact us at [email protected] to stop receiving them or unsubscribe using the link included in the e-mail. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations. Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions.

THIRD PARTY LINKS

Our website may contain links to other websites which are not under the control of 公司. We are not responsible for the privacy practices or content of such other websites. We encourage our users to be aware when they leave our website and to read the privacy statements of each website to which we may link that may collect Personal Information.

PRIVACY GOVERNANCE AND SECURITY

At 公司 we collect the minimum amount of data that is necessary for us to provide you with a product or service.

Privacy governance at 公司 is cross-functional and includes all areas of the company including customer and employee data. The Legal Team has a Senior Legal Counsel and General Counsel in charge of privacy compliance. The General Counsel reports directly to our CEO. In addition, senior representatives from Technology, Internal Audit, IT and Cybersecurity, and Product Marketing partner with the Privacy Legal team to help protect customer privacy as long as it remains under our control. This includes procedures for entering into Data Protection Agreements and to conduct Data Protection Impact Assessment/Privacy Impact Assessments, as required under applicable law.

All 公司 employees are required to take annual privacy training, corporate policies and internal controls training.

We maintain reasonable technical, physical and administrative security safeguards to protect Personal Information against loss and any form of unlawful processing (such as theft and unauthorized access). Any Personal Information you provide to us is exchanged on a secure server. Furthermore, our Sites/Services are secured by SSL-encryption to protect Personal Information from unauthorized access when transferring them over the Internet. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of information about you collected through the Sites/Services.

Adherence to 公司’s privacy and security standards may be subject to audit by 公司’s Internal Audit team.

Employees may email [email protected] to raise any privacy queries or questions they may have. A dedicated team, led by Privacy Legal team, manages all queries received to resolution.

CHILDREN’S PRIVACY

We do not knowingly collect Personal Information from children under 16 without permission from a parent or guardian. If we learn that we have collected the Personal Information of such a child, we will take steps to delete the information as soon as possible.

CHANGES TO THIS PRIVACY POLICY

公司 reserves the right, in its sole discretion, to change, modify, add or remove portions of this Privacy Policy at any time and from time to time. We will notify you of any material changes to our Privacy Policy as required by law. We will also post an updated copy on our website. Please check our site periodically for updates. Your continued use of our website means that you consent to the collection, use and disclosure of Personal Information as set out in the updated Privacy Policy.

HOW TO CONTACT US

We welcome your feedback. If you have any questions about this Privacy Policy, please contact 公司’s Chief Privacy Officer at: [email protected].