Privacy policy

This Privacy Policy (together with the Online TERMS AND CONDITIONS, CONDITIONS OF SALE, COOKIE POLICY and any other documents we refer to in this Privacy Policy or those Terms) explains how we, Imperial Tobacco Company Limited (d/b/a “Vuse”), may collect, use, disclose and otherwise process your personal information when you visit our website at  [https://www. vuse.com/ca/en] (‘Website’), visit one of our retail locations and when you otherwise interact with us.

For further information regarding our privacy practices when using our mobile application, please also see our MYVUSE APP PRIVACY POLICY.

We are committed to protecting and respecting your privacy.  Please read the following carefully.

Please refer to our COOKIE POLICY if you would like detailed information on the types of cookies we use on the Website, the purposes for which we use each cookie, how you can disable and enable the use of certain cookies and the consequences of doing so.

If you have any queries or concerns regarding this Privacy Policy, please contact us at INFO.CA@VUSE.COM.

What information do we collect about you

We collect and process the following data about you (‘your information’):

• information that you submit online via the Website, including when you set up a Vuse account;
• any correspondence you send to us when you contact us through email, telephone or the live chat function on our Website;
• details of your visits to the Website and the resources that you access (which may include, amongst other things, traffic data and communication data, information about the device and browser you use, your network connection and your IP address);
• details of transactions you carry out or orders you place through the Website and information that you submit online via the Website while placing your orders (which includes your name, email, shipping and billing address, payment details and phone number);
• information about your social media account when you engage with us on or through third-party social networking websites, plug-ins and applications, or when you access your social media account through our Website;
• details of your transaction and purchase history (if you have a Vuse account with us) when you purchase products at any of our retail locations;
• monitoring information recorded by our surveillance cameras when you visit any of our retail locations; and
• biometric identification information, such as a palm vein scan, if you choose to provide us with such information for the purposes of authentication.

Verifying your age

Website verification

As this Website relates to vaping and vaping products, users of the Website must be adults who have reached the legal age to purchase vaping products in their jurisdiction of residence (i.e. 18, 19 or 21 years of age, depending on the province/territory). Before you can purchase Vuse products from the Website, create a Vuse account or subscribe to Vuse news, offers and information, we must verify your age.

We use a third party consumer reporting agency to verify your age by confirming that the date of birth you provide to us matches the date of birth on your credit file (but we do not obtain any credit-related information from you).

Any verification check with a consumer reporting agency will be registered as a ‘soft inquiry’ on your credit report. A soft inquiry means that the search was not made for lending purposes and it is only included on your credit report so that you know the search was made. It does not affect your credit rating or score.

In-store verification

When you visit any of our retail locations you will be required to provide us with proof that you have reached the legal age to purchase vaping products in the jurisdiction of such retail location. We require a valid government ID to be shown as proof that you are legally permitted to purchase products at our locations. We do not scan your ID or take photos of it.

Outside the Province of Quebec, once you have completed our age verification processes outlined above, you may choose to participate in the optional palm vein scanner (biometrics) program, where our third-party service provider will collect a scan of your palm vein, which will be associated with your Vuse account. Once registered, when you visit any of our retail locations outside of the Province of Quebec, you may choose to scan your palm for authentication purposes, instead of completing the age verification processes outlined above. You may opt-out of the program at any time through your Vuse account, at which point we will delete your palm vein scan from your Vuse account and our records.

Research Projects and Surveys

From time to time, we may offer you the opportunity to participate in surveys, research or pilot projects, which may be administered through a third-party research company. If you participate in one of these activities, the third-party may collect information about your use of the Website, products and related services, as described to you when you sign-up for the survey, research or pilot project. We receive information about these surveys and research studies in an aggregated, anonymized format. We may combine such survey data with other aggregate statistical information to help us provide tailored offers and to understand and improve the user experience across our products, services and Website..

What we do with the information we collect about you

We use your personal information in the following ways:

• to carry out our obligations arising from any contracts with you and for billing and delivery purposes;
• to ensure that the Website’s content is presented as effectively as possible for you; 
• for our internal purposes, such as quality control, Website performance, system administration and to evaluate use of the Website, so that we can provide you with enhanced services; 
• to notify you about changes to our services; 
• to provide you with information, products or services that you request from us, or which we feel may interest you; 
• to verify your age (see the section above for further details);
• to create a Vuse account for you;
• to provide you with a more seamless in-store customer experience (see the section on in-store verification above for further details);
• to send you marketing or promotional material;
• to enable you to participate in the features of the Website, when you choose to do so; and
• to ensure the safety and security of our retail locations.

Marketing

We may send you marketing communications by email if you sign-up to receive information about products, services and research opportunities relating to Vuse and other current and future brands distributed by Imperial Tobacco Company Limited that may be tailored to your preferences, purchases and app usage, including cart reminders. We may use aggregate statistical information to help us tailor our communications. You can withdraw your consent or unsubscribe at any time by following the unsubscribe instructions included in each communication, by contacting us at INFO.CA@VUSE.COM, by updating your preferences on the Vuse ACCOUNT DETAILS PAGE with the relevant checkbox during the Vuse account opening process. Please note that when you unsubscribe, you may continue to receive transactional or account-related communications from us.

Sharing your personal information

With whom do we share your information? We may share your personal information with other organisations, such as:

• With our parent company, any of our affiliates or other entities from the British American Tobacco (BAT) group;
• with tax, audit or other authorities;
• with our agents, mandataries, consultants, data processors and other service providers (including affiliates) if the personal information is necessary to allow these entities to provide services on our behalf. For example, we may use service providers to send email or other communications, host our website, provide live, on-screen assistance through CoBrowse (a technical support tool) at your request, conduct surveys, verify your age, authenticate your account, and manage and analyze data and our advertising effectiveness. In such cases, your personal information will be used to provide the specific services we request and will be kept confidential. Our service providers are given the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers maintain or process personal information in Canada, the US, EU and other jurisdictions. For additional information on the manner in which our service providers treat your personal information, contact us as set out below; 
• with your consent, we may disclose your email address to selected third parties for the purposes we specify when requesting your consent; 
• If you pay for a product over this Website, we use a third-party service provider to process your payment. Our third-party service provider operates secure servers to process your payment. They encrypt your payment card information and authorize payment directly. This means that your payment card details are never revealed to us.
• with certain third-parties as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Vuse or as part of a corporate reorganization or stock sale or other change in corporate control; or 
• along with our Canadian, US and other affiliates and service providers, as required or permitted by applicable law, such as in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), or to another organization in the case of a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property. 

Where do we transfer your information?

Your personal information may also be transferred outside of the Province of Quebec or outside of Canada to the third parties described in Sharing Your Personal Information.  We want to make sure that your personal information is stored and transferred in a way which is secure. We will therefore only transfer data outside of the Province of Quebec or outside of Canada where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data. We and our service providers may transfer your information to, or store it in, provinces or countries located outside the Province of Quebec or outside of Canada including the European Economic Area (‘EEA’) and the United States. Where we transfer your personal information outside the Province of Quebec or outside of Canada, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. For more information about how we or our service providers process your personal information, contact as us outlined below.

Safeguards

We have put in place a series of security safeguards designed to protect your personal information against loss and theft, as well as unauthorized access, disclosure, copying, use and modification, regardless of the format in which the information is held. 

These security safeguards include physical measures, administrative measures and technological measures that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored. 

We also take the necessary measures to ensure that all our managers and employees are informed on the contents of this Privacy Policy and requirements under applicable privacy legislation, and understand that they are required to conform to it at all times. Access to personal information is strictly limited on a need-to-know basis to the persons for whom such information is necessary for the performance of their functions and duties. Unauthorized access to or disclosure of your personal information by one of our employees is strictly prohibited and will result in appropriate disciplinary measures. 

We will keep your personal information for the time required to fulfill the identified purposes, our legitimate business purposes and to conform to legislative requirements. 

If you have a username, password or other login details that enable you to access certain parts of the Website, you must not allow any other person to use them and must treat them as confidential. If you believe or suspect that someone else knows your login details you must contact us at INFO.CA@VUSE.COM as soon as possible. Please also see our CONDITIONS OF SALE for more information. 

Website Information

We and/or our service providers collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information for statistical purposes and to help us understand our Website activity, and to monitor and improve our Website. We also use a technology called “cookies”. A cookie is a tiny element of data that our Website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our Website where you are prompted to log in or that are customizable. If you have accessed our Website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to deliver products and personalized content or services, and (3) will provide us and our service providers with information that we use to personalize our website in accordance with your preferences and to better understand our website activity. You may set your web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all features of our Website. To learn more about how we use cookies, please see our COOKIE POLICY for more details. 

We and our service providers (such as Google Analytics) also use cookies to help us understand your Website activity, to improve our Website and provide better customer service. For more information about Google Analytics, see WWW.GOOGLE.COM/POLICIES/PRIVACY/PARTNERS/. 

Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website. 

Our Website may contain links to other sites that we do not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information. 

CoBrowsing Sessions

When you activate a CoBrowse session on our Website, you enable one of our agents to view your active digital session in a limited capacity to provide you with on-screen assistance. Our agent will only be able to CoBrowse with you within our Website and will not be able to view other applications on your device. Your account password, credit card number and credit card verification code will be masked during the co-browsing session and our agent will not have access to this information.

Your rights

We recognize that it is important to keep personal information accurate, complete and up-to-date and we take reasonable steps to ensure the accuracy and completeness of the personal information we use and discloses. However, you are responsible for informing us at the contact information set out below of any change in your personal information which may occur during the course of our relationship. 

You have the right to request access to your personal information which is in our custody or control, subject to limited exceptions prescribed by law. You can also request that information which is inaccurate or incomplete be rectified. 

We will respond to every request for access and rectification, in accordance with applicable laws. In the event that we cannot provide access to or rectify your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions, and we will provide you with any recourse available. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time-to-time. We will post updates on the Website, and where appropriate, notify you about material changes by sending you an email with the modified terms or by posting a copy of them on the Website. Any changes will take effect on the date on which we post the modified notice on the Website.

How to contact us

If you wish to contact us with any queries or concerns about this Privacy Policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to our collection of your personal information, please see our CONTACT US page or email us at INFO.CA@VUSE.COM or contact our Privacy Officer at:

Imperial Tobacco Company Limited

3711, St-Antoine Street West

Montréal (Québec)

H4C 3P6

DATA_PROTECTION_DONNEES@BAT.COM