This Privacy Policy (the “Policy”) sets out how Browns Shoes Inc. collects, uses, discloses, and stores your personal information. For ease of reference, we refer to ourselves as Browns or simply “we”.
Our Policy applies regardless of how we collect your personal information, for example, in person, by telephone, through e-mail, or via our website.
When appropriate or necessary, we will provide you with additional information relating to the processing of your personal information before collecting your personal information.
By accepting our Policy or by providing us with personal information after you have had an opportunity to review our Policy or any supplemental notice, you consent to our processing of your personal information in accordance with our Policy and the relevant supplemental notice.
How to contact our Privacy Officer?
Our Privacy Officer may be reached at:
By email:
privacy@brownsshoes.com
By mail:
2255 Cohen Street
Saint-Laurent, Québec, H4R 2N7
Attn: Privacy Officer.
How do we use your personal information?
The way we will process your personal information will depend on the nature of your interaction with us. Below you will find a description of how we process your personal information, provided however that we may further process your personal information as provided in applicable privacy laws.
When you browse our website
How will we collect your Personal Information?
Unless you allow us to do so, we will not collect any personal information when you browse our website.
When you set your personal preferences and want us to remember them, we will rely on the attributes of the different products you view.
What Personal Information do we collect?
If you want us to do so, we will collect your personal preferences derived from the attributes of the products you view on our website (for example: type of product, color, brand, size).
From whom do we collect your Personal Information?
We will collect your personal information directly from you.
Why do we collect and use your Personal Information?
To enhance your experience when you browse our website and suggest products that would be relevant to your interests and preferences.
How can you refuse that we collect your Personal Information and what are the consequences of such refusal?
We will not be able to recommend products that may be of interest to you.
Who will have access to your Personal Information?
Store employees when you visit one of our store.
If you need assistance after completing your transaction, customer care representatives who will log into our CRM to assist you; and
Our fraud prevention team may have access to your personal information.
How will we share your Personal Information with third parties?
We rely on service providers who provide cloud-based software and infrastructure to store and process your personal information on our behalf.
If you allow us to do so, we will share your email address as well as the different products that may be of interest to you with Meta and Google to present you with ads and promotions that would be relevant to you.
We also rely on third party service providers to help us understand your preferences and what are the products that you may like.
How long will we retain your Personal Information?
We will retain your personal information as long as you have an account with us.
When you create an account or subscribe to our mailing list
How will we collect your Personal Information?
We will collect your personal information when you:
- create an account on our web.
- sign-in your account.
- subscribe to our mailing list;
Your personal information will be collected using forms on our website.
What Personal Information do we collect?
The personal information we collect will depend on the form your are completing on our website. Broadly, we collect your name, postal address, email address, phone number, date of birth and password.
From whom do we collect your Personal Information?
In most situations, we will collect your personal information directly from you.
If you decide to create an account or sign-in your account through a social media provider, we will collect your personal information from the operator of the social media platform used to log-in your account.
Why do we collect and use your Personal Information?
To create your account;
To update you on events and promotional materials, and to send requested materials;
To process your subscription to our mailing list and send you emails.
How can you refuse that we collect your Personal Information and what are the consequences of such refusal?
You have no obligations to create an account or subscribe to our mailing list, both are on a voluntary basis. We will not be able to create your account or send you emails.
Who will have access to your Personal Information?
Store employees when you visit one of our store; and
Our fraud prevention team may have access to your personal information.
If you need assistance after completing your transaction, customer care representatives who will log into our CRM to assist you.
How will we share your Personal Information with third parties?
We rely on service providers who provide cloud-based software and infrastructure to store and process your personal information on our behalf.
We rely on a service provider to build audiences and send our mailing list.
Will your personal information be shared outside the Province of Quebec?
Yes, it is possible that your personal information will be communicated outside of the Province of Quebec when we communicate your personal information to one of our service providers.
How long will we retain your Personal Information?
We will retain your personal information as long as you have an account with us.
When you complete a transaction on our website
How will we collect your Personal Information?
We will collect your personal information when you:
- complete a purchase;
- sign-in your account;
Your personal information will be collected using forms on our website.
Your payment information is sent directly to our payment processor and we only receive and retain a confirmation token of the transaction as well as the last four digits of your credit card.
What Personal Information do we collect?
The personal information we collect will depend on the form your are completing on our website. Broadly, we collect your name, postal address, email address, phone number, date of birth, password, and credit card information.
If you want us to do so, we will collect your personal preferences derived from the attributes of the products you view on our website (for example: type of product, color, brand, size).
From whom do we collect your Personal Information?
In most situations, we will collect your personal information directly from you.
If you decide to create an account or sign-in your account through a social media provider, we will collect your personal information from the operator of the social media platform used to log-in your account.
Why do we collect and use your Personal Information?
Process your transaction;
Understand your needs and preferences to better assist you;
Contact you to inform you that we have received your products;
Remember the products that you have purchased;
Assess the legitimacy of the transaction and mitigate the risk of fraud.
How can you refuse that we collect your Personal Information and what are the consequences of such refusal?
We will not be able to process your order and deliver the products you wanted to buy.
Who will have access to your Personal Information?
Warehouse employees who will process your order when we don’t have the product(s) you wanted in our store; and
If you need assistance after completing your transaction, customer care representatives who will log into our CRM to assist you.
Our fraud prevention team may have access to your personal information.
How will we share your Personal Information with third parties?
We rely on service providers who provide cloud-based software and infrastructure to store and process your personal information on our behalf.
We rely on a service provider to build audiences and send our mailing list.
We also rely on payment processors to process your credit card information when you purchase products from us.
Will your personal information be shared outside the Province of Quebec?
Yes, it is possible that your personal information will be communicated outside of the Province of Quebec when we communicate your personal information to one of our service providers.
How long will we retain your Personal Information?
We will retain your personal information as long as you have an account with us.
When you complete a transaction in one of our stores
How will we collect your Personal Information?
We will collect your personal information when you purchase products.
It is possible that some of your personal information also be collected from you while we assist you finding the products you are looking for.
What Personal Information do we collect?
On a voluntary basis, we collect your name, email address and phone number when you purchase products from our one of our stores.
Your payment information is sent directly to our payment processor and we only receive and retain a confirmation token of the transaction as well as the last four digits of your credit card.
From whom do we collect your Personal Information?
In most situations, we will collect your personal information directly from you.
We may however collect your personal information from a third party that you designated to handle a return or an exchange on your behalf.
Why do we collect and use your Personal Information?
Process your transaction;
Understand your needs and preferences to better assist you;
Contact you to inform you that we have received your products;
Remember the products that you have purchased;
Assess the legitimacy of the transaction and mitigate the risk of fraud.
How can you refuse that we collect your Personal Information and what are the consequences of such refusal?
You can inform our store personnel that you do not want to provide your personal information.
We will not be able to associate a transaction with your account and be able to enhance your shopping experience with tailored recommendations and personalized experience.
Who will have access to your Personal Information?
Store employees who assist you while you’re in our store;
Warehouse employees who will process your order when we don’t have the product(s) you wanted in our store; and
If you need assistance after completing your transaction, customer care representatives who will log into our CRM to assist you.
Our fraud prevention team may have access to your personal information.
How will we share your Personal Information with third parties?
We rely on service providers who provide cloud-based software and infrastructure to store and process your personal information on our behalf.
We also rely on payment processors to process your credit card information when you purchase products from us.
When you allow us to do so, we will share your email address and general categories of products you purchased with Meta and Google to assess the effectiveness of our ad campaigns.
Will your personal information be shared outside the Province of Quebec?
Yes, it is possible that your personal information will be communicated outside of the Province of Quebec when we communicate your personal information to one of our service providers.
How long will we retain your Personal Information?
We will retain your personal information as long as you have an account with us.
When you seek customer service
How will we collect your Personal Information?
We will collect your personal information when you interact with one of our customer care team member, either via email, our call center or our live chat tool.
What Personal Information do we collect?
We collect your name, email address and order number
From whom do we collect your Personal Information?
In most situations, we will collect your personal information directly from you.
We may however collect your personal information from a third party that you designated to handle a return or an exchange on your behalf.
Why do we collect and use your Personal Information?
Validating your identity to ensure that we are speaking with the right person;
Access your transaction history;
Process invoice when you wish to return a product;
To respond to your inquiries.
Send you a confirmation that the replacement products were shipped, Sending you replacement products.
How can you refuse that we collect your Personal Information and what are the consequences of such refusal?
If we can’t validate your identity, we cannot process any request that is beyond the scope of a general inquiry.
Who will have access to your Personal Information?
Customer Care representatives who will log into our CRM.
How will we share your Personal Information with third parties?
We rely on service providers who provide cloud-based software and infrastructure to store and process your personal information on our behalf.
We also rely on payment processors to process your credit card information when you purchase products from us.
Will your personal information be shared outside the Province of Quebec?
Yes, it is possible that your personal information will be communicated outside of the Province of Quebec when we communicate your personal information to one of our service provider.
How long will we retain your Personal Information?
We will retain your personal information as long as you have an account with us.
When you apply to join our team
How will we collect your Personal Information?
We will collect your personal information when you apply for a position within Browns:
- through a jobs posting websites (i.e. LinkedIn, Indeed, Wirkn);
- through your social media account if you chose to apply via said social media platform;
- through our website when you apply online;
- through our printed application form.
What Personal Information do we collect?
We collect the personal information contained in your resume, cover letter and any additional material you may provide to us as part of the recruitment process. The personal information will also vary depending on the way you applied for the job. We may also collect personal information about your academic and professional background.
From whom do we collect your Personal Information?
In most situations, we will collect your personal information directly from you.
If your application is submitted through a recruiting firm, we will collect your personal information from the recruiting firm that referred you.
We may also collect your personal information through employees when you are referred.
We may also collect personal information about you from your references, your past employers, your school, and other third-party service providers we use for background checks.
If you applied through a third-party platform, we will collect your personal information from the operator of the social media platform used to apply.
Why do we collect and use your Personal Information?
To communicate with you; and
To evaluate your application for the position.
How can you refuse that we collect your Personal Information and what are the consequences of such refusal?
We collect only the personal information (i) you choose to share with us, (ii) that is provided by one of your reference; or (iii) that is publicly available. We need to process a minimum of personal information, otherwise we won't be able to evaluate your application and communicate with you.
Who will have access to your Personal Information?
We restrict access to your personal information to our employees who need to have access to it as part of the recruitment process (human resources, internal team members related to the posted position, technical and administrative support).
How will we share your Personal Information with third parties?
We rely on service providers who provide cloud-based software and infrastructure to store and process your personal information on our behalf.
Will your personal information be shared outside the Province of Quebec?
Yes, your personal information will be communicated outside of the Province of Quebec when we communicate your personal information to one of our service providers.
How long will we retain your Personal Information?
We will retain your personal information for the duration of the evaluation process of your application, in accordance with our record retention calendar.
When you are an employee within our organisation
How will we collect your Personal Information?
In addition to the personal information we collected as part of the recruitment process, we will collect personal information throughout your employment with us.
- Through your communications with us via email, on the phone or in person;
- through one of our or third parties portals;
- Through one of our forms; and
- through any discipline, merit, or performance review processes.
What Personal Information do we collect?
We will collect personal information linked to your:
- identity such as your name, email address, postal address and social insurance number;
- identification and authentication in our IT systems, such as your username and password;
- your work performance; and
Furthermore, we may collect additional information throughout your employment for specific reasons or events.
From whom do we collect your Personal Information?
In most situations, we will collect your personal information directly from you.
We might also collect information from your manager and other employees.
We may also collect personal information automatically through your usage of our IT systems.
Why do we collect and use your Personal Information?
To communicate with you;
To pay you;
To track your performance and determine any monetary raises or promotions; and
To maintain your employee record.
How can you refuse that we collect your Personal Information and what are the consequences of such refusal?
We need the personal information collected from you in order to maintain your employment relationship, as further detailed in your employment contract.
Who will have access to your Personal Information?
We restrict access to your personal information to our employees who need to have access to it as part of human ressources operations (human resources, payroll associated staff, your manager and technical and administrative support).
How will we share your Personal Information with third parties?
We rely on service providers who provide cloud-based software and infrastructure to store and process your personal information on our behalf.
We use a third-party to handle our payroll.
We will share your personal information with the relevant government for tax purposes.
Will your personal information be shared outside the Province of Quebec?
Yes, your personal information will be communicated outside of the Province of Quebec when we communicate your personal information to one of our service providers or when we communicate your personal information with the Federal Government.
How long will we retain your Personal Information?
We will retain your personal information as long as you remain an employee within Browns , in accordance with our record retention calendar once you cease to be employed by Browns.
Minors under 14 years of age
We do not voluntarily collect personal information from individuals under the age of 14.
If you are a minor under the age of 14, you may not provide us with personal information without the express consent of a parent or guardian.
If you are a parent or guardian and you become aware that your child has provided us with personal information, please contact our Privacy Officer.
If we discover that we have collected personal information from someone under the age of 14 without the consent of the parent or guardian, we will take appropriate steps to delete such information from our systems.
How long will we retain your personal information?
We will hold your personal information until the purposes for which it was collected have been fulfilled. However, we may hold your personal information for a longer period when required in order to comply with our legal and regulatory obligations to hold or preserve information or records.
For more information on how long we hold personal information, please contact our Privacy Officer in accordance with the information provided in section 1 hereto.
You understand therefore that your consent is valid for this period, unless you exercise your right to withdraw your consent, with the consequences that such a request entails, as described below.
Security measures and inherent risks
We take the appropriate security measures to protect your personal information. More specifically, we have implemented physical, technical and administrative protection safeguards to ensure the protection of your personal information.
We will never contact you to request information about your credit card number or bank account. This information is only sent to Browns when you complete a transaction. If you receive a suspicious e-mail with a link to update your account information, do not click on the link. Access your account directly via our website. If you receive an unsolicited e-mail asking you to confirm or provide your password or personal or banking information, ignore the request and contact us immediately.
For security reasons and to prevent fraud, credit card orders placed through our website will only be accepted if the billing name and address match the name and address on your credit card. If the information does not match, your order will be refused, even if the transaction has been pre-authorized by your bank.
Despite these measures, given the inherent risks inherent related to the usage of computer systems, we cannot ensure or guarantee the security and confidentiality of any personal information you transmit or provide to us, and you do so at your own risk.
If you have reason to believe that personal information has been compromise, please contact our Privacy Officer.
What rights you have toward your personal information?
You have several rights with respect to your personal information. Specifically, you have the following rights:
Access to your personal information
You may ask us whether we hold any personal information about you and, if so, request access to that personal information.
If you have an account with us, you may access your personal information by logging in your account on our website.
Rectification
You may request to rectify any inaccurate or incomplete personal information we hold about you.
If you have an account with us, you may update and correct your personal information by logging in your account on our website.
Consent withdrawal
You may withdraw your consent to the communication or use of the personal information we hold about you.
However, you understand that if you do so, we might be unable to fulfill your order or process any return or exchange for a product you bought. Depending on the extent of your consent withdrawal, we may decide to delete your account.
Portability
Effective on September 22, 2024, you may request that the personal information you provided us about you be communicated to you or transferred to another organization in a structured, commonly used technological format.
You may request a copy of the personal information you have provided to us by contacting our Privacy Officer.
How can you exercise your rights?
To exercise any of your rights, please contact our Privacy Officer.
Our Privacy Officer will need to confirm your identity before able to process your request.
How can you make a complaint about our handling or processing of your personal information?
Browns takes inquiries, complaints and comments about our handling and processing of your personal information very seriously. We invite you to contact our Privacy Officer if you have any complaints or comments about how we protect your personal information.
Your complaint will be reviewed by our Privacy Officer, who will determine whether our handling of your personal information complies with our privacy program and any applicable laws.
Our objective is to do our best to resolve your complaint. We aim to answer to every complaint politely, promptly and ideally within 30 days.
You may also file a complaint with the Commission d'accès à l'information du Québec using the form available here. However, we invite you to contact our Privacy Officer first.
External sites or services
This Policy does not apply to any third-party websites, pages or applications that may be accessed through our products and services and we are not responsible for such third-party services. If you click or follow such links, these third-party sites or services will likely have their own privacy policies that you should review before submitting your personal information.
How do we update this Policy?
We may modify our Policy from time to time in our sole discretion to reflect changes in our business practices or changes in applicable laws.
We will publish a modification notice on our website, along with a summary of the upcoming changes before any modifications to our Policy enter into effect. The modifications will become effective on the date specified in the relevant change notice.
Approval and effective date
This Policy was approved by the Privacy Officer on [@] and is effective as of [@].
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Summary of our policy on governance of personal information
Browns is committed to protecting your personal information throughout its life cycle in accordance with its privacy program and the requirements of applicable laws.
As such, in addition to our Privacy Policy, Browns has adopted a policy on governance of personal information, the purpose of which is to set out the principles governing the protection of personal information in our operations.
The objectives of our governance policy are to:
- ensure proper, safe, compliant and transparent treatment of your personal information;
- establish guidelines relating to the processing of personal information by Browns throughout its lifecycle; and
- define roles and responsibilities of the Privacy Officer and those of our employees.
Roles and responsibilities
Because respecting your privacy is everyone's business at Browns, our Privacy Officer is supported by a multidisciplinary team that includes members of each of our business units as well as external consultants.
Each member of our staff has a role to play in ensuring that we act in accordance with our values and our privacy program. In fact, every member of our staff is called upon to :
- direct any questions or comments about how we handle or should handle your personal information to the Privacy Officer;
- treat your personal information as if it was their own personal information; and
- participate in training and awareness-raising activities on the importance of the protection of personal information.
Governance guidelines
Browns recognizes the importance of the protection, the confidentiality and the security of the personal information it processes in the course of business. Browns also recognizes the importance of making its employees and partners aware of this.
Browns has prepared guidelines of good and prohibited practices regarding the ways in which we may handle your personal information, for example:
- we identify the purposes and objectives for which we collect your personal information. Thereafter, your personal information is used only in accordance with those purposes;
- if we identify new purposes, we will seek your express consent to allow us to process your personal information in accordance with these new purposes, unless otherwise permitted by law;
- we only collect the minimum amount of information necessary to fulfill the identified purposes;
- we strive to obtain your consent when we collect your personal information, and where sensitive personal information is involved, we seek your express consent;
- we display our privacy policy clearly and prominently when we collect your personal information through technological means;
- we ensure that our technology products or services that include privacy settings offer the highest level of privacy by default, without requiring any action on your part;
- we do not use technologies that allow identification, localization or profiling without disclosing this practice and informing you on how to activate such features;
- we ensure that your personal information is complete and up-to-date when we use it;
- we carry out privacy impact assessments when required by law, and when we consider that the processing of your personal information involves risks to your privacy;
- where reasonably possible, we restrict access to your personal information only to those members of our staff and our service providers who need to have access to it in the course of our operations;
- we do not disclose your personal information to third parties without your consent, except where permitted by law.
Confidentiality incident
Browns implemented a process to respond and to process a confidentiality incident.
In accordance with this process, Browns must take reasonable steps to reduce the risk of serious harm and review its practices to prevent future confidentiality incident of similar nature.
Browns registers all confidentiality incidents in an incident register and will adjust its privacy program as necessary following a confidentiality incident.
