Privacy Policy

1. Privacy Policy
We take pride on protecting the privacy of our clients, employees, contractors, and business associates. This Privacy Policy explains how POND collects, holds, uses, and transfers personal information in the course of its business. It also sets out individuals’ rights regarding their personal information that we hold. Personal information is any information about an identifiable individual. This includes a person’s age, address, opinions, and financial details. However, the name, title, business address, and contact information of an employee in an organization are not personal information.
2. Principles
We do not collect personally identifiable information unless we first ask you for it. We may request that you voluntarily supply us with information, including your e-mail address, street address, telephone number, or other information so that we may enhance your site visit or follow up with you after your visit. Whether you provide any information is entirely up to you. If you have voluntarily provided information, you consented to the collection and use of your personally identifiable information as described in this Privacy Policy. You may at any time withdraw your consent with respect to the collection and use of your personal information as described in this Privacy Policy. In some circumstances, POND may share information you voluntarily provide us with authorized business partners. We do not sell or rent personally identifiable information collected through this site to anyone. During the period you are logged onto our site, we log IP addresses, browser and platform types, domain names, access times, referral addresses, and your activity while using or reviewing our site. As stated in this Privacy Policy, POND may also disclose information in special cases when we have a good faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect and defend our rights or property; (c) enforce the Web site Terms and Conditions of Use; or (d) act to protect the interests of our users or others.
3. Definitions

• “Data Controller” (or “Owner”): the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Website. The Data Controller, unless otherwise specified, is the Owner of the Website, as described below:

POND Detergent G.P.
4762 Cartier Street
Montreal, Quebec H2H 1X1

• “Data Processor” (or “Data Supervisor”): The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this Privacy Policy. The Data Processor’s contact information is the following:
■ SSL server database formabase

• “Data Subject”: the natural person to whom the Personal Data refers;
• “Document”: the Privacy Policy and the Cookie Policy;
• “Legal Information”: This Document has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This Privacy Policy relates solely to the Website, if not stated otherwise within this Document;
• “Personal Data”: any information to an identified and identifiable natural person;
• “Service”: the service provided by the Owner;
• “Usage Data”: information collected automatically through the Website, which includes IP addresses, browser and platform types, domain names, access times, referral addresses, and the User’s activity on the Website;
• “User” (or “You”): The individual using the Website who, unless otherwise specified, coincides with the Data Subject;
• “We” and “us”: refers to ■ Inc.; and
• “Website”: www.■.com, which is how the Personal Data of the User is collected and processed.

4. Type of Personal Data Processed
The Personal Data that we process includes names, e-mail addresses, user IDs, mailing addresses, IP addresses, first and last name, postal code, credit card number, credit card expiration date, credit card CVN code, browser and platform types, domain names, access times, referral addresses and the User’s general activity on the Website.
Unless specified otherwise, all Personal Data requested by the Website is mandatory and failure to provide this Personal Data may make it impossible for the Owner to provide its Service. In cases where the Website specifically states that some Personal Data is not mandatory, Users are free not to communicate this Personal Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
If you have voluntarily provided Personal Data, we may, from time to time, send you mail or e-mail regarding products and services.
5. Mode and Place of Processing
Methods of processing
The Personal Data is sent to us through the Website. The User’s purchase information (i.e. credit card number) is invisible on the Website and our servers. The safety of such information is being taken care of by the payment processors (PayPal, Visa, MasterCard, etc.). The Client’s other Personal Data (i.e. name, address, etc.) is sent and processed on a server secured by SECTIGO.

Legal basis for processing
The Owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This does not apply whenever the processing of Personal Data is subject to European data protection law;
• Provision of the Personal Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which the Owner is subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; and
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Personal Data is stored on the North American cloud and on a server that is in Montreal Canada.
Any Personal Data that you submit to the Website may be sent electronically to a server for our Website. As such, the Personal Data may be used, stored, or processed outside the country where it was recorded.
Recipients of the Personal Data
The only recipients of the Personal Data are the Owner and its business partners.

Retention time or the criteria to determine such time
Personal Data shall be processed and stored for the period necessary to achieve the purposes they have been collected for.
Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed or until the termination of the contract; and
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. The Owner may also be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
6. Purposes of Retention
Our only purpose for which we process Personal Data is for direct sales and marketing activity related to our products and services. The Personal Data could be used for marketing purpose with the consent of the Users obtained via Cookies, POND’s Terms and Conditions, or this Privacy Policy. A notice shall be visible on the Website with respect to the collection of data in order to enhance your visit or for marketing purposes.
7. Rights of Users

Users have the following rights with respect to their Personal Data:
• Withdraw the consent they have previously given at any time;
• Object to the processing of their Personal Data;
• Have access to their Personal Data;
• Verify and demand an update or a correction of the Personal Data;
• Restrict the processing of their Personal Data;
• Have their Personal Data deleted or otherwise removed without undue delay;
• Receive Personal Data or have it transferred to another controller; and
• Bring a claim before the competent data protection authority.

How to exercise these rights

The User can exercise his rights by contacting the Owner through the contact details provided in this Privacy Policy. These rights can be exercised free of charge and will be addressed by the Owner as early as possible and always within one (1) month following the reception of an enquiry from the User.

8. Additional information about the Personal Data collection
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in a legal action or in the stages leading to possible legal action arising from improper use of the Website or the related Service.
The User acknowledges that the Owner may be required to reveal Personal Data upon request of public authorities.
Additional information about the User’s Personal Data
In addition to the information contained in this policy, the Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, the Website and any third-party services may collect files that record interaction with the Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this Privacy Policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information of the Owner at the beginning of this Privacy Policy.
Changes to this Policy
The Owner reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and possibly within the Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

How do we protect your Personal Data?
We use reasonable commercial efforts to protect the User’s Personal Data. This includes, among other things, using industry standard techniques such as firewalls, encryption, intrusion detection, and site monitoring. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us or receive from us. This is especially true for Personal Data transmitted via e-mail. We have no way of protecting that information until it reaches us. Once we receive your transmission, we make our best effort to ensure its security on our servers. Internally, we will restrict access to the User’s Personal Data to employees and authorized business partners who need access to the Personal Data in order to do their jobs. These employees and authorized business partners are limited in number and are committed to our Privacy Policy.
How can you help protect your Personal Data?
If you are using the Website for which you are registered and chose a password, we recommend that you do not divulge his password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also remember to sign out of the Website by closing your browser window when you have finished your work. This is to ensure that others cannot access your personally identifiable information and correspondence if others have access to your computer.
What about links to other sites?
The Website may contain links to other sites, including those of our authorized business partners. While we seek to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other sites.

COOKIE POLICY
1. Definitions
Please refer to the Definitions section in the Privacy Policy.
2. What are Cookies
The Website utilizes a standard technology called “Cookies” to collect Personal Data about how the Website is used. Cookies are designed to help the Owner determine that a particular User has visited the Website previously and thus save and remember any preferences that may have been set while the User was browsing the Website. Cookies are small strings of text that the Website can send to the User’s browser.
Cookies cannot retrieve any other data from your hard drive or obtain your e-mail address. If you are simply browsing the Website, a Cookie may be used to identify your browser as one that has visited the site before. We may also make use of memory-based Cookies in support of authenticating the User. Similarly, if you are a registered user of a site providing service to the Owner’s clients (and have a user ID and password), we may use Cookies so that we can provide Personal Data based on preferences you have indicated while using the site.
Some of the purposes for which Cookies are installed may also require the User’s consent.
Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this Document.
3. Warning
Although you have the ability to modify your browser to either accept all Cookies, notify you when a Cookie is sent, or reject all Cookies, it may not be possible to utilize the Website or the service which require registration if you reject Cookies.
We do not follow your browsing path outside of the Website, except for referral data discussed above. Advertising networks that serve ads onto the Website may also use their own Cookies. We have no access or control over these Cookies.
4. Purposes
Cookies are used for the following:
• Collect information about how the Website is used;
• Help the Owner determine that a particular User had visited the Website and thus save and remember any preferences that may have been set while the User was browsing the Website;
• Carry out other activities that are strictly necessary for the operation of the Website, for example in relation to the distribution of traffic; and
• Save browsing preferences and to optimize the User’s browsing experience.

5. How to provide or withdraw consent to the installation of Cookies
In addition to the information contained in this this Document, the User can manage preferences for Cookies directly from within their own browser and prevent third parties from installing Cookies.
Also, through browser preferences, it is possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this Website.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers (Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer).
With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party’s privacy policy, or by contacting the third party.
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