American Greetings Corporation Web Site Terms of Service
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Purpose of this Policy
This Policy describes the way that Carlton Cards Limited (Canada) will, subject to applicable legal requirements, adhere to all relevant federal and provincial legislative privacy requirements. The Policy follows the 10 Canadian Standards Association (CSA) principles identified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). The Policy describes each principle and the method of implementing each. Carlton Cards Limited (Canada) will strive to meet or exceed federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws. Any and all changes will immediately be posted to the Carlton Cards Limited (Canada) web site.
To better understand our policy, Carlton Cards Limited (Canada) has set out some basic definitions to use when reading and interpreting the principles below:
- Collection – the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.
- Consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Carlton Cards Limited (Canada). Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
- Customer – an individual who uses, or applies to use Carlton Cards Limited (Canada)’s products or services, where such individual is a residential customer or an individual carrying on business alone as a sole proprietorship or in partnership with other individuals.
- Disclosure – making personal information available to a third party.
- Personal information – information about an identifiable individual that is recorded in any form, but does not include aggregated information that cannot be associated with a specific customer. For a customer, such information does not include information that is aggregated in such a manner that it cannot be connected to him/her and/or information which is publicly listed in a written or online directory or typically made available through directory assistance.
- Third party – an individual or organization outside Carlton Cards Limited (Canada).
- Use – the treatment, handling, and management of personal information by and within Carlton Cards Limited (Canada).
- The Privacy Officer’s identity will be fully disclosed and publicly accessible to Carlton Cards Limited (Canada) members and the public in general. Carlton Cards Canada Limited’s Privacy Officer is firstname.lastname@example.org.
- Carlton Cards Limited (Canada)’s Privacy Officer will ensure that Carlton Cards Limited (Canada) manages all personal information in its possession in accordance with this Policy including that which may be transferred to a third party. Third party organizations who handle information on behalf of Carlton Cards Limited (Canada) shall be contractually obligated to adhere to the standards of Carlton Cards Limited (Canada).
- Security measures at all levels designed to protect personal information in our possession;
- Implementing procedures designed to respond to complaints and/or inquiries;
- Identifying Purposes, Type of Information Collected and Website
- Carlton Cards Limited (Canada) shall only collect the information reasonably necessary to perform the services and deliver the product as agreed to with its customers. Access to our Privacy policies and procedures will be readily available. Similarly, the process by which challenges may be made to Carlton Cards Limited (Canada)’s compliance and/or adherence to the legislation in question shall be readily available and transparent. To obtain further information, contact Carlton Cards Limited (Canada)’s Privacy Officer.
- Carlton Cards Limited (Canada) collects personal information from its customers and members of the public for the following purposes.
- to collect personal information for the purposes of extending credit or providing refunds to its customers and prospective customers and monitoring the credit of its customers in respect of providing its goods and services, and to verify the accuracy of information provided to us for both of the purposes of credit and refunds, including the establishment of customer identification;
- to identify products or services of value to current, past and prospective customers and to sell or promote such products and services of Carlton Cards Canada Limited, including direct marketing to provide ongoing service and improve service;
- to assist in the administration of our Loss Prevention Program and to protect you and us from error and fraud and so as to comply with legal and regulatory requirements;
- Carlton Cards Limited (Canada) will use the personal information for the uses specified above in section 2 and in Sections 3.2 and 3.3 below.
- In addition to using personal information for the providing of security services, Carlton Cards Limited (Canada) may from time to time wish to use customer names, addresses and contact information for the purposes of providing promotional opportunities, including by providing the information to Carlton Cards Limited (Canada)’s marketing and sales departments and other third parties who Carlton Cards Limited (Canada) believes provide services or goods that may be of interest to you. Carlton Cards Limited (Canada) and any such third parties may contact you to with promotions. Carlton Cards Limited (Canada) will provide an opportunity for the recipient to consent to these opportunities during the registration process. If you consent but later wish to opt out of this use of information later, you may do so by contacting us as described at Section 3.3 below.
- If at any time you wish to withdraw your consent to the use of your information for any purposes, you may do so by contacting the Privacy Officer for Carlton Cards Limited (Canada). We will do our best to accommodate your request in a timely fashion without diminishing the services we provide to you. We will explain to you the impact of your withdrawal on any services we provide to you.
- Carlton Cards Limited (Canada) may collect personal information without consent where reasonable to do so and where permitted by law.
- Limiting Collection
- Carlton Cards Limited (Canada) shall not indiscriminately collect information. The amount and type of information we collect shall be limited to that which is required to fulfill our identified purposes. Certain information, such as driver’s license, although convenient for identification, is voluntary. It is up to you whether you want to provide this or other suitable identification.
- Carlton Cards Limited (Canada) will not use any form of deception in gaining personal information from its customers.
- Limiting Use, Disclosure and Retention
- Subject to applicable legislation, Carlton Cards Limited (Canada) shall limit use of personal information it collects to purposes that we have disclosed in Sections 2 (Identifying Purposes) and 3.2, (Consent), and shall not, without the customer’s express or implied consent, disclose the personal information to any third persons, except:
- Carlton Cards Limited (Canada) may disclose the personal information collected by it to a government authority that has asserted its lawful authority to obtain the information or where the association has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court, person, or body with jurisdiction to compel the production of the information or otherwise as permitted by applicable law;
- Carlton Cards Limited (Canada) may at its discretion release personal information for the purposes of collecting debts which may be owed to Carlton Cards Limited (Canada) and may disclose in this regard the personal information it collects to credit reporting agencies;
- Carlton Cards Limited (Canada) may promise to share its customers’ information with its affiliated and association corporations, including American Greetings Corporation and Carlton Cards U.S.;
- in certain circumstances, Carlton Cards Limited may have to collect, use, discharge or release personal information for its protection. For example, it may do so to detect or prevent fraud.
- Carlton Cards Limited (Canada) shall maintain documents for certain periods of time dependant upon necessity.
- Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by Carlton Cards Limited (Canada).
- Subject to applicable legislation, Carlton Cards Limited (Canada) shall limit use of personal information it collects to purposes that we have disclosed in Sections 2 (Identifying Purposes) and 3.2, (Consent), and shall not, without the customer’s express or implied consent, disclose the personal information to any third persons, except:
- Carlton Cards Limited (Canada) shall strive to ensure to the extent it can that the information entrusted to us is maintained in an accurate manner. We shall try to maintain the interests of the individual and attempt to ensure that decisions are not made for or about an individual based on personal information that is flawed.
- Security safeguards have been implemented to ensure that the personal information collected by Carlton Cards Limited (Canada) is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.
- The level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected. The more sensitive the information, the higher the level of security employed.
- Methods of protection and safeguards to be employed shall include but in no way be necessarily limited to locked files, offices and storage areas, security clearances and need to know access as well as technological measures such as passwords and encryption.
- Carlton Cards Limited (Canada) will, upon request, disclose the methods by which it handles personal information.
- The information available includes:
- The name address and phone number of the Carlton Cards Limited (Canada) Privacy Officer;
- The forms which one may use to access one’s information or change your information;
- A description of the type of personal information held by Carlton Cards Limited (Canada) and our general uses thereof.
- Individual Access
- Subject to applicable legislation, upon request by the individual concerned Carlton Cards Limited (Canada) shall disclose whether or not it actually holds personal information on an individual. We shall disclose the source of this information when requested and provide an account of third parties to whom the information may have been disclosed.
- Carlton Cards Limited (Canada) may request sufficient information to confirm your identity before releasing your personal information to you.
- Subject to applicable legislation, Carlton Cards Limited (Canada) shall endeavour to provide this information within 30 days of receipt of the information requested and only charge nominal fees for the purpose of off-setting its expenses incurred in supplying the requested information. This information shall be provided in an understandable format, at the time you make a request.
- Any inaccurate information that is brought to our attention shall be corrected by Carlton Cards Limited (Canada) as quickly as possible and any pertinent third parties shall be apprised of the corrections in due course.
- Challenging Compliance
- Upon receipt of a complaint Carlton Cards Limited (Canada) shall make available the complaint procedures which will be simple and easy to access.
- Carlton Cards Limited (Canada) shall investigate all complaints. If the complaint is deemed justified Carlton Cards Limited (Canada) shall take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.
- All complaints shall be addressed to the Carlton Cards Limited (Canada) Privacy Officer.
Accessibility for Ontarians with Disabilities Act (AODA) Policy
This policy is intended to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005, and applies to the provision of goods and services to the public or other third parties.
Statement of Commitment
Carlton Cards Limited strives to provide goods and services in a manner that is accessible to all our customers, internal and external stakeholders, and third parties in a way that respects the dignity and independence of people with disabilities. We are also committed to giving persons with disabilities the same opportunity to access our goods and services and to benefit from those services, in the same place and in a similar way as other individuals.
The Company will continue adhere to the applicable provincial legislation.
This policy applies to all Associates that deal with customers, members of the public or other third parties on behalf of Carlton Cards Limited, including when the provision of goods and services occurs off the premises of Carlton Cards Limited.
This policy shall also apply to contingent workers, (agency contractors, third party, etc) who work in Ontario or others who provide service in Ontario regardless of where they are located, as well as volunteers and third parties who interact with the public on behalf of Carlton Cards Limited in Ontario.
This policy applies not only during standard business hours, but to any activities on or off Carlton Cards Limited premises which could reasonably be associated with the workplace.
The section of this policy that addresses the use of guide dogs and service animals only applies to the provision of goods and services that take place at premises owned/operated by Carlton Cards Limited.
This policy is only affiliated to Carlton Cards Limited and does not apply to retail stores that have Carlton Cards name associated to them. Carlton Cards retails divisions are owned and operated independent of Carlton Cards Limited.
Assistive Devices – are tools, products or types of equipment that help perform tasks and activities; an Assistive Device is any device that helps someone do something that they might not otherwise be able to do well or at all. Generally the term is used for devices that help people overcome a handicap such as a mobility, vision, mental, dexterity or hearing loss (e.g. canes, crutches, wheelchairs or hearing aids).
Disability (as per the Ontario Human Rights Code) – “disability” means,
- any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
- a condition of mental impairment or a developmental disability,
- a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
- a mental disorder, or
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997; (“handicap”)
Persons with Disabilities – individuals who have a disability as defined under the Ontario Human Rights Code.
Support Persons – are any person, whether a paid professional, volunteer, family member, or friend, who accompany a person with a disability in order to help with communications, personal care or medical needs, while accessing goods or services.
Service Animals – are animals individually trained to do work or perform tasks for the benefit of a person with a disability.
Carlton Cards Limited is nationally respected for its ability to provide its customers with high quality products, great prices, and excellent customer service. Carlton Cards Limited supports the full inclusion of persons with disabilities as set out in applicable legislation.
Carlton Cards Limited will use reasonable efforts to ensure that its policies, programs and procedures are consistent with the following principles:
- Dignity – Goods and services are provided in a manner that respects the dignity and independence of persons with disabilities; i.e. treating them as customers who are as valued and as deserving of high quality and timely service as any other customer.
- Independence – freedom from control or influence of others, freedom to do things in one’s own way.
- Integration – Goods and services to persons with disabilities and others must be integrated with the provision to others, unless an alternative measure is necessary to allow persons with disabilities to fully benefit from the same services in the same or similar way as other individuals. The alternative measure may be temporary or permanent.
- Equal Opportunity – Persons with disabilities are provided the same opportunity to obtain, use, and benefit from Carlton Cards Limited’s goods and services.
- Communication – Communication with persons with disability are conducted in a manner that takes the person’s disability into account.
In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 429/07, this policy addresses the following:
- The Provision of Goods and Services to People with Disabilities
- The Use of Assistive Devices
- The Use of Service Animals
- The Use of Support Persons
- Notice of Service Disruptions
- Customer Feedback
- Document Formats and Location of Customer Service Policy
A. The Provision of Goods and Services to People with Disabilities
Carlton Cards Limited is committed to excellence in servicing all customers including people with disabilities and we will carry out our functions and responsibilities utilizing every reasonable effort to:
- _Take into account individual needs when providing goods and services;
- _Communicate in a manner that takes into account the customer’s disability;
- _Ensure that all customers receive the same value and quality of customer service experience;
- _Allow customers with disabilities to do things in their own way, at their own pace when accessing goods and services as long as this does not present a safety risk; and
- _Use alternative measures when possible to ensure that customers with disabilities have access to the same services, in the same place, and in a similar manner.
B. The Use of Assistive Devices
Carlton Cards Limited is committed to servicing persons with disabilities who use assistive devices to obtain, use or benefit from our goods and services. Persons with disabilities may use their own assistive devices when accessing goods and services provided by Carlton Cards Limited.
In cases where the assistive device presents a safety concern, other reasonable measures will be used to ensure the access of goods and services.
Carlton Cards Limited will ensure that our Associates are trained and familiar with various assistive devices that may be used by customers, internal and external stakeholders, and third parties, with disabilities while accessing our goods and services.
C. The Use of Service Animals
A customer with a disability that is accompanied by a guide dog, service animal or service dog will be allowed access to premises that are open to the public and other third parties. “No Pet” policies do not apply to guide dogs, service animals and/or service dogs.
Carlton Cards Limited will also ensure that all Associates dealing with the public or third parties are properly trained on how to interact with persons with disabilities who are accompanied by a service animal.
If there is a conflict that arises concerning a service animal on site (e.g. with another staff member who is allergic or fearful about an animal), Managers will work with the parties to find an acceptable solution. The best solution will be one that respects each individual’s right to a safe, secure and accessible environment.
D. The Use of Support Persons
Carlton Cards Limited is committed to welcoming people with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to enter Carlton Cards Limited premises open to the public or other third parties with his or her support person. At no time will a person with a disability who is accompanied by a support person to be prevented from having access to his or her support person while on our premises.
In situations where confidential information might be discussed, consent will be obtained from the customer, prior to any conversation taking place in the presence of the support person.
When support persons are required (e.g. sign language interpreters, real-time captioners, attendants) for Carlton Cards Limited sponsored meetings, consultations or events, Carlton Cards Limited will arrange to pay support persons directly for their time.
E. Notice of Service Disruptions
Carlton Cards Limited will provide individuals with notice in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available.
When disruptions occur, Carlton Cards Limited will post notices in conspicuous places including at the point of disruption, at the main entrances, and at reception counter, and the nearest accessible entrance to the service disruption and/or on the Carlton Cards Limited website. Customers with scheduled appointments will be contacted; or verbally notify customers when they are making appointments, or by any other method that may be reasonable under the circumstances.
Carlton Cards Limited will provide training to all Associates, who deal with the public, or other third parties, and all those who are involved in the development and approval of customer service policies, practices and procedures.
Training will include the following:
- A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005.
- A review of the requirements of the Accessibility Standards for Customer Service, Ontario Regulation 429/07.
- Instructions on how to interact with people with disabilities who:
- May or may not use assistive devices
- May or may not require the assistance of a guide dog, service dog or other services animal; or
- May or may not require the use of a support person (including the handling of admission fees).
- Instructions on what to do if a person with a disability is having difficulty accessing our services.
- Carlton Cards Limited’s policies, procedures and practices pertaining to the provision of customer service to customers with disabilities.
To create awareness and to ensure compliance, AODA training is mandatory and will be provided to all applicable Associates. Management is responsible for ensuring that all Associates receive the AODA training.
All new Associates are required to complete the AODA training within 45 days of being hired.
Carlton Cards Limited will keep a record of training that includes the dates training was provided and the names of the Associates who attended the training.
G. Customer Feedback
Feedback regarding the way Carlton Cards Limited provides goods and services to persons with disabilities can be made verbally (in person or by phone) or in writing via mail, email, fax.
Complaints will be addressed according to the already established processes of Carlton Cards Limited.
All feedback will be directed to the Human Resources Generalist. Feedback will be used to improve customer service where applicable.
Title: Accessibility for Ontarians with Disabilities Act (AODA)
Policy, Standard and Procedures Page 5 of 5
The Human Resources Generalist will acknowledge receipt of the feedback within 5 business days and will provide a further response outlining actions taken within 10 business days. The responses will be given to the person who provided the feedback in the format requested by the customer or in the most appropriate format where no request was made by the person providing feedback.
H. Document Formats and Location of Customer Service Policy
All documents required under the Accessibility Standards for Customer Service, Ontario Regulation, 429/07 will be made available upon request to Carlton Cards Limited, Attention: Human Resources Generalist. Documents are also available in alternative formats. To make a request, the customer is asked to contact the Human Resources Generalist via an in person meeting, phone, mail, email, or fax.
The AODA policy is posted on the Employee Bulletin Board in Carlton Cards Limited Head Office and is also available for download on the Carlton Cards Limited intranet site under Human Resources > Company Policies.
Any questions about this AODA policy, the feedback process or availability of documents can be directed to:
Human Resources Generalist
Carlton Cards Limited
1820 Matheson Blvd
Mississauga, ON L4W 0B3
Application or Interpretation
Questions arising from this document should be directed to Management and the Human Resources Generalist for consultation.
The Company is committed to developing customer service policies that respect and promote dignity and independence of persons with disabilities. Therefore, no changes will be made to this policy before considering the impact on persons with disabilities.
Any policy of Carlton Cards Limited that does not respect and promote the dignity and independence of persons with disabilities will be modified or removed.
The Company reserves the right to add, delete, amend, or change any part or all of this policy at any time with or without notice.