Privacy policy


Privacy Policy

Expose Retail Strategies Inc. (“Expose”,“Our”, “Us”, or “We”) is committed to protecting theprivacy and security of your personal information obtained by reason of youruser relationship with Expose Retail Strategies Inc. and our application MyElane. This policy explains the types of customer personal information wecollect, how it is used, and the steps we take to ensure your personalinformation is handled appropriately.

Our policies and practices have beendesigned to comply with the Personal Information Protection and ElectronicDocuments Act (Canada) and corresponding provincial privacy acts.

I.                   Who is Expose Retail Strategies Inc.?

For purposes ofthis Customer Privacy Policy, “Expose Retail Strategies Inc.” means the ExposeRetail Strategies Inc. corporation, and its affiliates and subsidiaries.

II.                 What is personal information?

Personalinformation is information that refers to an individual specifically and is recordedin any form. Personal information that we may collect from our users includessuch things as age, gender, date of birth, your location and purchaseinformation. Information about individuals contained in publicly availableprinted and electronic publications, such as telephone directories, is notconsidered personal information.

III.               We are accountable to you

Expose isresponsible for all personal information under its control, including anypersonal information that is transferred to third parties for processing,storage or other purposes. Our employees are accountable for compliance withthese privacy and security principles.

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

 Exposeidentifies the purpose for which your personal information is collected andwill be used or disclosed. If that purpose is not listed below, we will do thisbefore or at the time the information is actually being collected. As a user ofMy Elane, you will be deemed to consent to our use of your personal informationfor the purpose of:

1. communicatingwith you generally, including general information or updates relating to MyElane;

2. processingyour purchases, including tracking your location to provide continuous updatesto merchants, in respect of your purchase;

3. processingand keeping track of transactions with third parties and reporting back to you;

4. protectingagainst fraud or error;

5. providingproduct and services requested by you;

6. administeringand managing our business operations;

7. recommendingproducts and services via e-mail or other electronic means that we believe willbe of interest and provide value to you based on your purchase history;

8. performingstatistical analyses of user purchases and behaviour, in order to improvedesign and navigation and to gather marketing information for ourselves and toshare with third parties. Only aggregated data from these analyses, notindividual data, will be used for this purpose;

9. complyingwith legal and governmental requirements; and

10. fulfillingany other purpose that would be reasonably apparent to the average person atthe time we collect it from you.

Otherwise,Expose will obtain your express consent (by verbal, written or electronicagreement) to collect, use or disclose your personal information. You canchange your consent preferences at any time by contacting our user support teamand our employees can help direct your call to the appropriate departmentwithin Expose to change your preferences. Refer to the “How to contact us”section below for our contact information.

V.                 We limit collection of your personalinformation

Expose collectsonly the information required to provide services to you. Expose will collectpersonal information only by clear, fair and lawful means.

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

Examples of the information we collect and analyzeinclude the Internet protocol (IP) address used to connect your mobile deviceto the Internet; login; e-mail address; password; mobile device and connectioninformation, such as browser type, version and timezone setting, browserplug-in types and versions, operating system, and platform; purchase history;the full Uniform Resource Locators (URL) clickstream to, through, and from ourwebsite, including date and time; cookie numbers; products you viewed orsearched for; and the telephone number used to call our customer servicenumber. We may also use browser data such as cookies, Flash cookies (also knownas Flash Local Shared Objects), or similar data on certain parts of ourapplication for fraud prevention and other purposes. We may use software toolssuch as JavaScript to measure and collect session information, includingdownload errors, length of visits to certain pages, page interactioninformation (such as scrolling, clicks, and mouse-overs), and methods used tobrowse away from the page.

VI.               We limit disclosure and retention of yourpersonal information

Expose does notdisclose personal information to any organization or person for any reasonexcept the following:

1. we share yourpersonal information with third party organizations in order to process yourtransactions on My Elane;

2. we employother companies and individuals to perform functions on our behalf. Examplesinclude processing credit card payments, storage of information, analyzingdata, providing marketing assistance, and providing customer service. They haveaccess to personal information needed to perform their functions, but may notuse 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 othercountries and therefore may be subject to disclosure under the laws of thosecountries; and

3. as wecontinue to develop our business, we might sell or buy subsidiaries, orbusiness units. In such transactions, customer information generally is one ofthe transferred business assets but remains subject to the promises made in anypre-existing Privacy Policy (unless, of course, the customer consentsotherwise). Also, in the unlikely event that Expose or substantially all of itsassets are acquired, customer information of course will be one of thetransferred assets.

You are deemedto consent to disclosure of your personal information for those purposes. Ifyour personal information is shared with third parties, those third parties arebound by appropriate agreements with Expose to secure and protect theconfidentiality of your personal information.

Expose retainsyour personal information only as long as it is required for our businessrelationship or as required by federal and provincial laws.

VII.             We keep your personal information up todate and accurate

Expose keepsyour personal information up to date, accurate and relevant for its intendeduse. You may request access to the personal information we have on record inorder to review and amend the information, as appropriate. In circumstanceswhere your personal information has been provided by a third party, we willrefer you to that party (e.g. credit bureaus). To access your personalinformation, refer to the “How to contact us” section below.

VIII.           The security of your personal informationis a priority for Expose Retail Strategies Inc.

We take steps tosafeguard your personal information, regardless of the format in which it isheld, including:

1. physicalsecurity measures such as restricted access facilities and locked filingcabinets;

2. electronicsecurity measures for computerized personal information such as passwordprotection, database encryption and personal identification numbers;

3. revealingonly the last five digits of your credit card numbers when confirming an order.Of course, the entire credit card number is transmitted to the appropriatecredit card company during order processing;

4.organizational processes such as limiting access to your personal informationto a selected group of individuals; and

5. contractualobligations with third parties who need access to your personal informationrequiring them to protect and secure your personal information. It’s importantfor you to protect against unauthorized access to your password and your mobiledevice. Be sure to sign off when you’ve finished using any shared device.

IX. We areopen about our privacy and security policy

We are committedto providing you with understandable and easily available information about ourpolicy and practices related to management of your personal information. Thispolicy 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.

IX.               We provide access to your personalinformation stored by Expose

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

1. inform youabout 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 youwith access to your information so you can review and verify the accuracy andcompleteness and request changes to the information; and/or

3. make anynecessary updates to your personal information.

XI. How tocontact us

By e-mail at:

Expose respondsin a timely manner to your questions, concerns and complaints about the privacyof your personal information and our privacy policies and procedures.

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

PrivacyOfficer c/o Expose Retail Strategies Inc.

2 Trent Court

St Catharines,ON



Our businesschanges constantly, and this privacy notice will change also. We may e-mailperiodic reminders of our policy and conditions, unless you have instructed usnot to, but you should check our website frequently to see recent changes. Weare, however, committed to protecting your information and will nevermaterially change our policies and practices to make them less protective ofcustomer information collected in the past without the consent of affectedcustomers.