Exposé Retail Strategies Inc. (“Exposé“, “Our“, Us“, or “We“) is committed to protecting the privacy and security of your personal information obtained by reason of your user relationship with Exposé Retail Strategies Inc. and our application My Elane. This policy explains the types of customer personal information we collect, how it is used, and the steps we take to ensure your personal information is handled appropriately.

Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (Canada) and corresponding provincial privacy acts.


I. Who is Exposé Retail Strategies Inc.?


For purposes of this Customer Privacy Policy, “Exposé Retail Strategies Inc.” means the Exposé Retail Strategies Inc. corporation, and its affiliates and subsidiaries.


II. What is personal information?


Personal information is information that refers to an individual specifically and is recorded in any form. Personal information that we may collect from our users includes such things as age, gender, date of birth, your location and purchase information. Information about individuals contained in publicly available printed and electronic publications, such as telephone directories, is not considered personal information.


III. We are accountable to you


Exposé is responsible for all personal information under its control, including any personal information that is transferred to third parties for processing, storage or other purposes. Our employees are accountable for compliance with these privacy and security principles.


IV. We let you know why we collect and use your personal information and get your consent


Exposé identifies the purpose for which your personal information is collected and will be used or disclosed. If that purpose is not listed below, we will do this before or at the time the information is actually being collected. As a user of My Elane, you will be deemed to consent to our use of your personal information for the purpose of:

  1. communicating with you generally, including general information or updates relating to My Elane;
  2. processing your purchases, including tracking your location to provide continuous updates to merchants, in respect of your purchase;
  3. processing and keeping track of transactions with third parties and reporting back to you;
  4. protecting against fraud or error;
  5. providing product and services requested by you;
  6. administering and managing our business operations;
  7. recommending products and services via e-mail or other electronic means that we believe will be of interest and provide value to you based on your purchase history;
  8. performing statistical analyses of user purchases and behaviour, in order to improve design and navigation and to gather marketing information for ourselves and to share with third parties. Only aggregated data from these analyses, not individual data, will be used for this purpose;
  9. complying with legal and governmental requirements; and
  10. fulfilling any other purpose that would be reasonably apparent to the average person at the time we collect it from you.

Otherwise, Exposé will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your personal information. You can change your consent preferences at any time by contacting our user support team and our employees can help direct your call to the appropriate department within Exposé to change your preferences. Refer to the “How to contact us” section below for our contact information.


V. We limit collection of your personal information


Exposé collects only the information required to provide services to you. Exposé will collect personal information only by clear, fair and lawful means.

We receive and store any information you enter in the My Elane application or give us in any other way, except for credit card information which is processed by a third party. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features.

Examples of the information we collect and analyze include the Internet protocol (IP) address used to connect your mobile device to the Internet; login; e-mail address; password; mobile device and connection information, such as browser type, version and timezone setting, browser plug-in types and versions, operating system, and platform; purchase history; the full Uniform Resource Locators (URL) clickstream to, through, and from our website, including date and time; cookie numbers; products you viewed or searched for; and the telephone number used to call our customer service number. We may also use browser data such as cookies, Flash cookies (also known as Flash Local Shared Objects), or similar data on certain parts of our application for fraud prevention and other purposes. We may use software tools such as JavaScript to measure and collect session information, including download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.


VI. We limit disclosure and retention of your personal information


Exposé does not disclose personal information to any organization or person for any reason except the following:

  1. we share your personal information with third party organizations in order to process your transactions on My Elane;
  2. we employ other companies and individuals to perform functions on our behalf. Examples include processing credit card payments, storage of information, analyzing data, providing marketing assistance, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes. We may use service providers located outside of Canada, and, if applicable, your personal information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries; and
  3. as we continue to develop our business, we might sell or buy subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the unlikely event that Exposé or substantially all of its assets are acquired, customer information of course will be one of the transferred assets.

You are deemed to consent to disclosure of your personal information for those purposes. If your personal information is shared with third parties, those third parties are bound by appropriate agreements with Exposé to secure and protect the confidentiality of your personal information.

Exposé retains your personal information only as long as it is required for our business relationship or as required by federal and provincial laws.


VII. We keep your personal information up to date and accurate


Exposé keeps your personal information up to date, accurate and relevant for its intended use.

You may request access to the personal information we have on record in order to review and amend the information, as appropriate. In circumstances where your personal information has been provided by a third party, we will refer you to that party (e.g. credit bureaus). To access your personal information, refer to the “How to contact us” section below.


VIII. The security of your personal information is a priority for Exposé Retail Strategies Inc.


We take steps to safeguard your personal information, regardless of the format in which it is held, including:

  1. physical security measures such as restricted access facilities and locked filing cabinets;
  2. electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers;
  3. revealing only the last five digits of your credit card numbers when confirming an order. Of course, the entire credit card number is transmitted to the appropriate credit card company during order processing;
  4. organizational processes such as limiting access to your personal information to a selected group of individuals; and
  5. contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information. It’s important for you to protect against unauthorized access to your password and your mobile device. Be sure to sign off when you’ve finished using any shared device.


IX. We are open about our privacy and security policy


We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information. This policy and any related information is available at all times on our website, under Privacy or on request. To contact us, refer to the “How to contact us” section below.


X. We provide access to your personal information stored by Exposé


You can request access to your personal information stored by Exposé. To contact us, refer to the “How to contact us” section below. Upon receiving such a request, we will:

  1. inform you about what type of personal information we have on record or in our control, how it is used and to whom it may have been disclosed;
  2. provide you with access to your information so you can review and verify the accuracy and completeness and request changes to the information; and/or
  3. make any necessary updates to your personal information.


XI. How to contact us


By e-mail at: [email protected]

Exposé responds in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures.

If your questions, concerns, and complaints have not been resolved to your satisfaction or if you have further questions, you can contact our Privacy Officer by e-mail at:

[email protected] or by mail at:

Privacy Officer c/o Exposé Retail Strategies Inc.

2 Trent Court

St Catharines, ON


Our business changes constantly, and this privacy notice will change also. We may e-mail periodic reminders of our policy and conditions, unless you have instructed us not to, but you should check our website frequently to see recent changes. We are, however, committed to protecting your information and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.