Last Updated December 12, 2017.


The Carlu (“The Carlu”, “us”, “we”, or “our”) operates the https://www.thecarlu.com/ website (the “Service”) from Ontario, Canada. The information below informs you of our policy regarding the collection, use and disclosure of Personal Information when you use our Service. For the purposes of this policy, Personal Information means information that identifies you, except for contact information used to communicate with you in relation to your employment, business, or profession, such as your name, position or title, work address, work telephone number, work fax number or work email address.

We are committed to providing our clients, customers, members (“you”, “your” or “them”) with exceptional service. Providing exceptional service may require the collection, use and, at times, the disclosure of your Personal Information. Protecting your Personal Information is one of our highest priorities. While we have always respected your privacy and safeguarded Personal Information, we have taken steps to reinforce our commitment to this goal, continue to provide exceptional service to you, and comply with applicable law regarding the collection, use and disclosure of Personal Information.

Changes To This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the revised policy.

You are advised to review this policy periodically for any changes.  Changes to this policy are effective when they are posted, which date will appear at the top of this page.

If we make any material changes to this policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Collection, Use, Disclosure Of Personal Information/consent

The Personal Information we collect may include your name, email address, and phone number.

We collect Personal Information that is necessary for the following purposes:

  • To verify identity;
  • To meet regulatory requirements; and
  • To meet legal requirements applicable to the particular goods and services you request.

We obtain consent to collect, use and/or disclose Personal Information in a variety of ways depending on the nature of the Personal Information involved and the intended use or disclosure. In many cases, by providing us with your Personal Information, you are consenting to have it used in accordance with this policy. In some cases, the law requires us to have you confirm, by clicking a box or otherwise in writing or orally, that you consent to the use and/or disclosure of your information (to receive promotional information through electronic messages for example).  In some cases, we are permitted by law to use and/or disclose your Personal Information without your consent (see below).

Among other situations, we are legally permitted and may collect, use or disclose Personal Information without consent:

  • in an emergency that threatens an individual’s life, health, or personal security;
  • for certain purposes when the Personal Information is available from a public source;
  • to obtain legal or other professional services from our advisors;
  • for the purposes of collecting a debt or detecting, suppressing or preventing fraud or the contravention of a law of Canada or a province.

We will not sell your Personal Information to other parties except with your consent.  We rely on you to update your Personal Information so as to ensure the information we are using is accurate and complete. You may request access to and a correction to your Personal Information by writing to us as indicated in the “Contact Us” section below. Any such requests must be in writing and provide sufficient detail to identify your Personal Information and where applicable, the correction you are seeking.  Note that we are not required to correct Personal Information where we believe the information is accurate.  We will attach a note of disagreement to the affected Personal Information in any such case.

We are committed to protecting your Personal Information and may use passwords, encryption, firewalls, restricted employee access or other methods to do so, in our discretion. We will use appropriate security measures when destroying your Personal Information such as shredding documents or deleting electronically stored information, in our discretion.

Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used (as more particularly described below).

These third parties have access to your Personal Information only to perform these tasks on our behalf and we prohibit them from disclosing or using it for any other purpose. No analytic and/or ad serving services collect/use Personal Information for their own purposes.

Automated Collection – Log Data/cookies/Third Party Analytics

We may collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on particular pages and other statistics.

We use “cookies” to collect information. Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

We may use third party services such as Google Analytics that collect, monitor and analyze information akin to Log Data and the information collected through cookies in order to increase our Service’s functionality.

Google Analytics is a web analysis service provided by Google. Google utilizes the data it collects from your web browser, which may include user demographic information, to track and examine the use of the website, to prepare reports on its activities and share them with other Google services. For clarity, Google Analytics is not used to track, collect or upload any Personal Information. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Google collects cookie and usage data and processes such information in the United States. For more information on Google’s use of information collected through Google Analytics, including how to opt out of Google Analytics data collection, please see “How Google uses data when you use our partners’ sites or apps”, available at www.google.com/policies/privacy/partners/ and Google’s privacy policy, available at http://www.google.com/intl/en/policies/privacy/ and Google’s instructions  on installing the “Google Analytics opt-out browser add-on”, available at https://tools.google.com/dlpage/gaoptout.

Behavioral Remarketing

The Carlu uses remarketing services to advertise on third party web sites to you after you have visited our Service. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service. In certain circumstances, we will assume we have your consent to access, use or disclose Personal Information or browser type information if you do not instruct your web browser to refuse all cookies or to indicate when a cookie is sent or if you do not opt out of Google Analytics or other services, as indicated below.

Google

Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

As noted above, Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/about/ads/#568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Communications

We may send emails to the email address you provide to us to verify your Account, respond to your enquiries, to process your purchases and for informational and operational purposes, such as Account management, customer service or system maintenance. We may also use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, in accordance with applicable law. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us. Please note that even if you unsubscribe to marketing emails, we may still need to send you communications relating to your use of the Site, such as service announcements or Account information (where applicable).

Compliance With Applicable Law

As set out above, and for clarity, we will disclose your Personal Information where required by law, including in response to a subpoena, or if we believe that such action is necessary to comply with the law, or where such action is permitted by the law, for example in regard to disclosure to law enforcement. We will also disclose Personal Information where the disclosure is required to protect the security or integrity of our Service, for example to prevent any violation of the terms of use of our Service.

SECURITY

The security of your Personal Information is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.  You assume the risk of sending us any Personal Information you send through the Service.

Links To Other Sites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services and you use such sites and services at your own risk.

Children’s Privacy

Our Service is not intended for use by anyone under the age of 18 (“Minor”).

We do not knowingly collect Personal Information from Minors. If you are a parent or guardian and you are aware that your Minor has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Minors without verification of parental consent, we take steps to remove that information from our servers.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Bayview Village, South Parking Lot
2901 Bayview Ave., Suite 300
Toronto, ON
M2K 2S3

contact@oliverbonacini.com

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