Last Updated:  26 th October, 2020

Bradley Technology Canada Inc and its global subsidiaries and affiliates
value customers and respect their privacy. This Privacy Policy describes
collection, processing and/or use of customer information when you visit
the www.bradleysmoker.com website and related Bradley Smoker
websites, use our applications, or otherwise provide us with personal
information.  By using our Site, or by choosing to submit personal
information to Bradley Smoker, you signify your consent to all of the terms
of this Privacy Policy. If you do not agree with any terms of this Privacy
Policy, please do not use this Site or submit any personal information to
Bradley Smoker.

This Privacy Policy explains how Bradley Technologies (Canada) Inc.,
Bradley Smoker Inc. and Bradley Smoker USA Inc. (collectively, “Bradley”)
collect, use, disclose and retain personal information, including any
personal information that you may provide when you visit the
www.bradleysmoker.com website and related Bradley websites
(collectively, the “Site”), use our applications, or otherwise provide us with
personal information.  By using our Site, or by submitting personal
information to us, you signify your consent to all of the terms of this Privacy
Policy. If you do not agree with any of the terms of this Privacy Policy, you
must not use this Site or submit any personal information to Bradley.

In this Privacy Policy, “personal information” means information about an
identifiable individual (e.g. an individual’s name, postal address, telephone
number and email address), but does not include (to the extent permitted
by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.

We may share the personal information you provide to us with our global
subsidiaries and affiliates (the “Bradley Group“), but we will not use your
personal information other than as described in this Privacy Policy.

Please note that this Privacy Policy may be updated from time to time due
to technical updates and appropriate implementation of new technologies
and/or due to changes of the law. We will make any such changes to this
Privacy Policy by posting a new version of this Privacy Policy to our Site.

Bradley’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued interactions with Bradley after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information by Bradley as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any
changes since the last version.

1. Children

Bradley’s websites and applications (including, without limitation, the Site)
are intended for persons over 18 years of age and are not intended for
children. We do not knowingly collect personal information from children
under 18 years of age. If a child has provided us with personal information,
his or her parent or guardian may contact us using the contact information
provided in Section 11 below for the purpose of having this information
deleted.

2. Collection and Use of Your Personal Information

The types of personal information we collect, the ways in which we collect
it, and the uses we might make of it, will vary depending on whether you
are visiting our Site for browsing purposes only (e.g. for viewing the
products we offer), placing an order for products or using specific services
or applications.

1. Use of Site for Browsing Purposes

If you use the Site for browsing purposes only, generally you are not
required to enter any personal information. We may automatically collect
certain information regarding your use of the Site, such as:

  • the date and time of your visit to the Site;
  • details regarding your use of the Site;
  • the type of browser you are using;
  • your browser settings;
  • the operating system you are using;
  • the website last visited by you;
  • the data volume transmitted and the access status (file transmitted, file not found, etc.); and
  • your IP address.

If you use the Site for browsing purposes only, we collect and use this data
in non-identifiable form only. This is done to generally enable the use of the Site as well as for statistical purposes and for improving our web presence
and the services we provide on the Site.

2. Shopping at the Site / Use of Specific Services

We collect personal information if you voluntarily provide it to us in connection with placing an order for products, interacting with our customer service/online consumer care team, or opening a customer account. The personal information we collect includes, but is not limited to, your contact information (such as your name, email address, postal address and phone number), payment card information, communications preferences, and correspondence you send to us. You can choose not to provide certain personal information to us, but then you might not be able to proceed with your intended interaction or transaction with us or receive the full benefit of the desired product or service.

We use the personal information we collect for purposes relating to or arising from your relationship and transactions with us, and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

  • to operate our Site in accordance with its terms and conditions;
  • to facilitate, complete or confirm, a purchase you choose to make using the Site, including facilitating payment for your purchase;
  • to notify you when an order you have made using the Site is ready for delivery or shipping;
  • to ship your order to your designated shipping address;
  • to respond to your questions or inquiries;
  • to conduct market research and surveys;
  • to conduct promotional activities, including contests;
  • to facilitate sign up, payment for, and execution of classes or events;
  • to improve our products, services and the Site;
  • to supply you with requested information about our products;
  • to send you informational or promotional communications that you have agreed to receive;
  • to carry out other purposes that are disclosed to you and to which you consent;
  • to comply with legal and regulatory requirements; and
  • to carry out any other purpose permitted or required by law.

3. Email List

If you opt in to participate in our email list (through the Site or any other channel), from time to time we may provide you with news and information about Bradley or the products and services we offer that might be of interest to you (as we may determine through our analysis of your personal information). Our newsletters and list serve email messages will be facilitated by a third party, which may include, but is not limited to, Active Campaign, a cloud-based marketing and sales automation software solution with features for email marketing, lead scoring and web analytics, a CRM platform, and a live chat messaging platform called Conversations. The software uses customer data to create customised messaging. Active Campaign may, furthermore, use this data to optimise and improve their services or for other purposes described in its privacy policy at https://www.activecampaign.com/legal/privacy-policy. You can revoke your consent to receive these commercial electronic communications at any time by clicking on the appropriate link contained in any such email communication. Your opt-out does not apply to emails that relate to Site information (including policy updates), legal notice, purchases, customer service/online consumer care matters, or that are automatically generated non-commercial messages (e.g. confirmation emails, order receipts etc).

4, Third Party Applications and Systems

Bradley uses certain third party applications and systems, which you may interact with or link to in connection with your use of the Site.  This Privacy Policy only addresses the collection, use, disclosure and retention of personal information by Bradley.  Bradley has no responsibility or liability for, or control over, any third party applications or systems, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by any third party applications or systems.  If you have any questions about how those applications or systems collect, use, disclose or retain personal information, you must contact the owner or operator of the applicable application or system.

The third party applications and systems that Bradley currently uses include, but are not limited to, the following:

Zapier

Zapier is a global remote business communication system that allows end users to integrate the web applications they use. Please review Zapier’s privacy policy here: https://zapier.com/privacy.

Slack

Slack is a customer relationship management system (CRM) offering many IRC-style features, including persistent chat rooms (channels) organized by topic, private groups, and direct messaging. Content, including files, conversations, and people, is all searchable within Slack. Users can add emoji buttons to their messages, on which other users can then click to express their reactions to messages. Please review Slack’s privacy policy here: https://slack.com/intl/en-ca/privacy-policy.

ManyChat

ManyChat is a Facebook Messenger marketing tool that lets you create bots for customer interaction for marketing, sales and support. Please review ManyChat’s privacy policy here: https://manychat.com/privacy.html.

Google DialogFlow

Google DialogFlow is an automated intelligent natural language processing system for Facebook Messenger’s customer support system. Google DialogFlow gives users new ways to interact with their product by building engaging voice and text-based conversational interfaces, such as voice apps and chatbots, powered by AI. Users can connect via website, mobile app, the Google Assistant, Amazon Alexa, Facebook Messenger, and other popular platforms and devices. Google DialogFlow’s Terms of Use can be found here: https://cloud.google.com/security/gdpr.

BufferBuffer provides a social media management tool that enables users to release posts on social platforms (Facebook, Instagram, Twitter, ect) at a scheduled time, in addition to other design and analytics tools to help improve user’s social media content. Please review Buffer’s Privacy Policy here: https://buffer.com/legal.

4. General Maintenance

Bradley may use your personal information (identifiable and non-identifiable) in order to improve the delivery of services to you, to ensure accuracy of data, or otherwise to perform maintenance or upgrades to the Site and Bradley’s other systems and services, including through use of reputable third party service providers.

3. Non-Personal Information

Bradley creates and collects non-personal information (i.e. information that is not about an identifiable individual), including personal information that has been aggregated or otherwise de-personalized so that the information no longer relates to an identifiable individual. We may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then we will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with personal information.

4. How We Disclose Personal Information

Bradley may disclose your personal information for purposes relating to or arising from your relations or transactions with us and as otherwise set out in this Privacy Policy or permitted by applicable law.

We may disclose your personal information in accordance with any express or implied consents that you give during your interactions and transactions with us.

We may disclose your personal information to our suppliers and service providers to assist us in the provision of products, services and information to you, to obtain products, services or information, or to assist us in using your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.

We may disclose your personal information as required or authorised by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. We may disclose your personal information to law enforcement agencies or other independent organizations if we reasonably believe the disclosure is necessary or appropriate in connection with law enforcement, national security or other issues of public importance, or if we reasonably believe the disclosure is necessary or appropriate to protect and enforce our legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of Bradley or others (including to detect and prevent fraud and other illegal activities, enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of Bradley’s products or services).  We have no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom we disclose the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

5. Retention of personal information

If Bradley collects your personal information, we will retain that personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with our legal obligations or enforce or protect our legal rights, or a longer period required or permitted by applicable law. We will delete or dispose of your personal information, or depersonalize the information, when we are no longer reasonably required to retain the personal information for the purposes set out in this Privacy Policy.

6. Use of cookies

We use cookies to enhance the Site. Cookies are small text files which your browser creates from data sent by our web server while you are visiting the Site. Your browser stores the cookies on your computer for subsequent retrieval. We use the following classes of cookies:

1. Session Cookies

We may use “session cookies” (also called temporary cookies), which are cookies that are only stored for the time you are using the Site. The purpose of these cookies is to identify your computer while you are visiting the Site, even while changing from one of our websites to another, and to determine the end of your visit. The cookies are deleted as soon as you have closed your browser session.

  • Tracking and Targeting Cookies

We may also use tracking and targeting cookies on the Site, which monitor a user’s behaviour. For that purpose we only use so-called “First-Party” cookies, which are cookies that will not be made available by your browser to any domains other than the Site. These cookies are used for the following purposes:

  • Page view/Page impression – analysing how often the website is visited;
  • Clickstream or Clickpath analysis – tracking the movement of the user on the website (e.g. identifying the path through which a user came to a certain product);
  • Ad Impressions and Click Through – analysing how often an advertisement banner is shown and clicked on;
  • Mouse movement and Heatmaps – tracking the mouse movement of the user and identifying where a particular high occurrence of clicks took place; and
  • Fraud detection and user testing.

You can set your browser to either allow or not allow these cookies. If you wish, you may completely deactivate the storage of cookies or only allow their storage for specific websites, or configure your browser so as to cause the browser to automatically send you a message as soon as a cookie is to be placed, asking for your permission regarding that cookie. Please note: if you wish to use the full scope of features of the Site, the use of certain cookies will be required.

  • Use of Google Analytics

The Site uses Google Analytics, which is a web analytics service of Google Inc. (“Google”). Google Analytics also uses cookies as part of its services. The information generated by the cookie about your use of the Site is normally transmitted to and stored on a Google server in the USA.  You can prevent the collection and recording of the data pertaining to your use of the Site that is generated by the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in which is available under the following link:

https://tools.google.com/dlpage/gaoptout?hl=en

For more detailed information regarding the terms and conditions of use and data protection, please visit:

https://support.google.com/analytics/answer/6004245?hl=en

  • Google AdWords

The Site uses Google AdWords, which is another analytics service of Google, and, in the context of Google Adwords, it uses Conversion Tracking. Google AdWords uses cookies for Conversion Tracking on the hard drive of your computer (a “conversion cookie“) as soon as you click on an advertisement placed by Google. If you visit certain pages of the Site, Google and Bradley are able to recognize that you have clicked on the advertisement and were referred to the Site.  The information obtained by means of the conversion cookies is intended for the preparation of statistics for AdWords customers using conversion cookies. Through these statistics we can determine the total number of users who have clicked on the advertisement placed by Google and have visited a page to which a conversion tracking tag was added.  For more detailed information on the terms and conditions of use and data protection in connection with Google AdWords, please go to:

https://www.google.com/policies/technologies/ads/.

7. Social Media Plug-ins

When you visit the Site, as a rule, no data is automatically transmitted to social networking sites (e.g. Facebook, Twitter etc). Please note, however, that with your consent Bradley may provide customer list, website visit, and marketing opt-in information that you have provided us (including your email address) to Facebook and other social media networks in order to utilize services such as Facebook’s Custom Audience and pixel services. 

Otherwise, only after you have actively clicked the applicable link or button yourself, your Internet browser will establish a connection to the servers of the relevant social network. By clicking the appropriate link or button (e.g. “Like”), you give your consent to your Internet browser establishing a connection to the servers of the relevant social network and transmitting data relating to the use of the website to the relevant social network provider.  Once engaged with the relevant social networking website, your use and browsing will be governed by the data protection statements/privacy policies of the relevant providers. Here are some useful links to the privacy policies of popular social media platforms:

https://www.facebook.com/policy.php

https://www.instagram.com/about/legal/terms/api/

https://twitter.com/en/privacy

https://policy.pinterest.com/en/privacy-policy

https://www.youtube.com/about/policies/#community-guidelines

You are solely responsible for the personal information that you choose to post or share on any social networking site. We have no control over, or responsibility or liability for, the use, disclosure or retention of the personal information that you disclose on any social networking site, and the use, disclosure and retention of the disclosed information is not subject to this Privacy Policy.

8. Protection of Personal Information and Data Security

If Bradley collects your personal information, we will use reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in our possession or under our control to help protect the information from unauthorised access, collection, use, disclosure, deletion or similar risks.  Our security measures are continuously being improved as new technologies become available and following our regular review of our current data security, access and protection practices. Personal information may be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by applicable law.

Although we have taken measures to help protect our Site, computer systems and any personal information that we have collected from unauthorised use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. Security risks cannot be eliminated and we cannot guarantee that your personal information will not be accessed, used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

Some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in Australia, the United States and the European Union, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to applicable laws in those jurisdictions.

9. Accuracy and Access to Personal Information

Bradley will rely on you to ensure that the personal information you provide to us is as accurate, complete and up-to-date as possible.  You must promptly notify us of any changes to the personal information you provide to us using the procedures made available for that purpose by us or by contacting us using the contact information provided in Section 11 below.

You may reasonably request access to your personal information collected by us and information about our use, disclosure and retention of that personal information by submitting a written request to us using the contact information provided in Section 11 below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information revised as appropriate. We may require you to verify your identity before we provide you with access to your personal information. You may also be required to pay a reasonable fee for access to your personal information.

We will use reasonable efforts to comply with your access or correction request; however, in some cases we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons. In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your personal information. 

We may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.

10. Third Party Sites

The Site may contain links to other third party websites. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any such third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit.  Any links from this Site to other websites, or references to products, services or publications other than those of Bradley, do not imply the endorsement or approval of such websites, products, services or publications by Bradley.

11. Questions and Legal Notice

If you have any questions or comments regarding this Privacy Policy, please send an email to our Australian distributor Hark Enterprises Pty Ltd at [email protected],com.au. Or you can email [email protected] or write to Bradley Smoker attn.: Privacy Officer, 8380 River Road, Delta, BC, V4G 1B5, CA.