In this Policy, “Personal Information” means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, mailing address, e-mail address, telephone number, or any other contact details. Data we collect with personal identifiers removed, so that the information no longer allows the individual to be identified directly or indirectly, is not considered to be Personal Information.

HHSL will only collect Personal Information that is pertinent and necessary to manage the Customer Relationship and will limit the collection of Personal Information to what is reasonably necessary to fulfill the purposes for which it was collected.

The types of Personal Information we collect depends on the nature of the Customer Relationship, and largely falls into three (3) categories:

1. Personal Information we collect directly from you;

2. Personal Information we collect automatically; and

3. Personal Information we collect from other parties.

This Policy applies to the collection of all Personal Information, regardless of how the information is obtained.

PERSONAL INFORMATION WE COLLECT DIRECTLY FROM YOU

HHSL will collect Personal Information directly from you throughout the duration of the Customer Relationship. The types of Personal Information we collect directly from you may include:

Basic Identifying Information Full name (first and last), date of birth, postal address, e-mail address, phone number, username, social media handle, or other similar identifiers.

Profile Information Customer ID, contractor status (as applicable), lifestyle and personal interest information, store and language preferences, account status, activation date, products added to your Wishlist, or in the case of Beaver Homes & Cottages, model preferences and specifications added to Scrapbook, and your subscription to a loyalty program that we participate in.

Transaction Information The type of products or services purchased, returned, or exchanged, order details, delivery information, deposits and total amount charged, payment information, the use of gift cards, and loyalty card information, including the amount points rewarded or redeemed.

Demographic Information Age, gender, and marital status.

Communications Information The date, time, and content of direct communications with us, including customer service inquiries, survey responses, online comments, product reviews, and testimonials.

PERSONAL INFORMATION WE COLLECT AUTOMATICALLY

HHSL may automatically collect certain types of Personal Information through various technologies when you use or access our websites, e-mails or visit HHSL stores. The types of Personal Information we collect automatically from you may include:

Device and Network Data Device hardware number, browser type, IP address, operating system version, language settings, unique device identifiers, serial numbers, screen resolution, usage, and traffic data, how your device interacts with our websites, network information and mobile network data.

Usage Data Your activity on our websites and with our e-mails using cookies, web beacons, pixel tags, and other tracking technologies, including, access dates and times, pages or screens viewed, searches made, and interactions with our e-mails. Refer to the COOKIES AND OTHER TRACKING TECHNOLOGIES section for more information about tracking technologies and how to establish your preferences.

Audio and Visual Information Images, videos, and recordings of your voice when you visit HHSL stores or for customer service quality assurance. We may collect audio and visual information, or a likeness thereof, through the participation in HHSL contests, challenges, surveys, reviews, or events.

Location Data Information that allows us to track your approximate location by manually providing the location information or enabling your mobile device to send us the approximate location.

PERSONAL INFORMATION WE COLLECT FROM OTHER SOURCES

HHSL may collect Personal Information about you from other sources that we have a relationship with, including:

Home Hardware Dealers Point-of-sale transactional data, customer account information, product and service complaints and, with your consent, basic identifying information to distribute commercial marketing materials.

Customer Referrals Full name (first and last) and e-mail address when you have been referred by someone with an existing Customer Relationship.

Carriers Updated delivery and address information, which we use to correct our records.

Social Platforms Behavioural and demographic information when you use or interact with our advertisements through Meta (formerly known as Facebook), X (formerly known as Twitter), Instagram, TikTok, Google, Pinterest, etc.

Other Third-Parties Behavioural and basic identifying information from analytics companies, marketing and advertising service providers and fraud prevention service providers.

PERSONAL INFORMATION WE DERIVE

HHSL may derive information or draw inferences about you based on the other types of Personal Information we collect or receive.

HHSL may use your Personal Information to ensure we are offering you the best products and services and to appropriately manage the Customer Relationship. We may use your Personal Information for various purposes, including:

PROVIDING PRODUCTS AND SERVICES

• Provide, administer, deliver, customize, support and improve the products and services we offer;

• Complete transactions for products and services and perform our contractual obligations, as applicable;

• Administer contests, challenges, promotions, events, and surveys;

• Manage online account profiles; and

• Respond to customer service inquiries, comments, or requests.

MARKETING, ADVERTISING AND RESEARCH

• Distribute customized promotions, offers and advertisements;

• Inform you about our products, contests, challenges, events, and promotions;

• Solicit feedback on products and services;

• Improve our product offer and presentation through tracking technology and analytics; and

• Conduct market research to better understand and manage our Customer Relationships.

SAFETY, SECURITY AND FRAUD PREVENTION

• Detect, prevent, or investigate malicious, fraudulent, deceptive, or other illegal or unlawful activity; and

• Identify, de-bug, and manage technical errors or disturbances that impact the use of our websites.

COMPLY WITH CONTRACTUAL, LEGAL AND REGULATORY OBLIGATIONS

• Comply with applicable legal and regulatory requirements;

• In the event of a corporate acquisition, merger, or other corporate transaction; and

• As otherwise permitted or required by applicable law.

AUTOMATED DECISION-MAKING

HHSL may use your Personal Information to make Automated Decisions2 to help provide you with products, services, and communications to enhance the Customer Relationship. For more information on the use of automated decision-making, please refer to the CONTACT US section.

2Automated Decisions involve the use of technology to make decisions with limited or no human involvement or intervention.

HHSL may disclose your Personal Information within our company, to affiliated companies, and to third party vendors, suppliers, and agents (“Service Providers”) that require the information to perform services on our behalf.

HHSL may share your Personal Information in the following circumstances:

HHSL Affiliates and Subsidiaries We may share Personal Information with HHSL affiliated companies and subsidiaries for the purposes set out in the USE OF PERSONAL INFORMATION section.

Service Providers To help us operate our business, technology systems and applications, internal procedures, infrastructure, marketing and advertising (including ad networks and social media platforms), loyalty program, data analytics, and other support services. These companies provide services such as data and website hosting, fraud detection, payment processing, administration of a loyalty program, customized advertising, analytics, and delivery processing.

We will limit the information shared with Service Providers to what is necessary for them to provide the service(s) and will prohibit them from using the information for any other purposes. Services Providers may use or combine the Personal Information shared with other information to improve their services. When your Personal Information is shared with a Service Provider, we require them to protect the information in a manner that is consistent with this Policy.

Some of our Service Providers may be located outside of Canada and may be subject to laws requiring them to disclose your Personal Information to government agencies, courts, and law enforcement in the jurisdiction they reside.

Corporate Transaction Personal Information may be disclosed or transferred as part of, or during negotiations of any transaction involving the transfer of some or all our business assets.

Lawful Interest Personal Information may be disclosed if required by law or valid court order, if the disclosure is necessary to enforce our agreements or policies, or the disclosure will protect the rights, property, or safety of HHSL, our customers, employees, and partners.

Consent and Authorization Personal Information may be shared with other parties with your consent or direct authorization.

NOTICE TO QUEBEC RESIDENTS

If you are a resident of Quebec, the Personal Information we collect about you will be communicated outside of Quebec and may be shared with Service Providers located within and outside of Canada in accordance with this Policy.

HHSL will rely on your consent to collect, use, store, and disclose your Personal Information, unless otherwise permitted under applicable law. The method of obtaining consent will depend on the circumstances and sensitivity of the information.

When you provide HHSL with your Personal Information, you understand and agree to HHSL’s collection, use, storage, and disclosure of your Personal Information in accordance with this Policy.

For information on withdrawing consent, please refer to the PRIVACY RIGHTS section.

MINORS

HHSL does not intend to or knowingly collect Personal Information from anyone under the age of 14 years old, or that falls within the definition of minor under applicable law. Information belonging to a minor will be removed from our systems.

HHSL is committed to protecting the security and confidentiality of all Personal Information under our control. We have implemented technical, physical, and administrative safeguards to protect against the loss and unauthorized access, use, modification, destruction, or disclosure of Personal Information.

HHSL will retain Personal Information for as long as necessary to fulfil the purposes for which it was collected, except where otherwise required or permitted by applicable law. Personal Information that is no longer required will be destroyed or anonymized in a secure manner and in accordance with applicable laws and regulations.

HHSL websites may contain links, plug-ins, and applications to third-party websites that are not controlled or operated by HHSL. Clicking a link or enabling a connection may allow third parties to collect information about you that is governed under their privacy policies. HHSL does not own or control these third-party websites and assumes no liability for their practices or policies.

HHSL may use cookies or other unique identifiers and technologies such as tracer tags, pixels, and web beacons to automatically collect information about how you interact with our websites and emails. The use of this technology allows HHSL to improve our websites, services, and marketing strategy to provide you with an enhanced customer experience.

More Information about Cookies

Cookies are small text files that are saved on your computer when you visit a website so that information can be saved. Cookies are used to make your online experience efficient by remembering information such as login credentials and user preferences.

Web beacons, also known as web bugs, pixel tags and clear gifs, are small images that communicate information from your device to a server.

For the purpose of this Policy, cookies, web beacons and all other tracking technologies are referred to as “cookies.”

HHSL uses the following types of cookies:

Strictly Necessary.

These cookies are essential and necessary for you to browse our websites and use their features, including access to areas of the websites, to add items to your cart, and enable fraud and security related functions.

Performance Cookies.

These cookies collect aggregated information about how you use our websites, including the pages you visit and the links you click.

Functionality Cookies.

These cookies allow our websites to remember choices you have previously made, including your login credentials, language preferences and preferred store.

You may control your cookie preferences on our websites by selecting Manage Cookie Consent on the websites or by deleting or disabling these technologies at any time through your browser. If you choose to disable or delete these technologies, some of the features on our websites may be unavailable or not function properly.

HHSL acknowledges and supports your right to exercise control over your Personal Information by making certain requests, as permitted by applicable laws. Depending on the nature of the Customer Relationship and your jurisdiction of residence, you may be entitled to:

Withdraw Consent

Withdraw your consent to HHSL’s collection, use, storage, and disclosure of your Personal Information. Depending on the circumstances, your consent withdrawal may prevent us from providing you or continuing to provide you with our products and services.

Data Access and Portability

Request access to, or copies of, your Personal Information that is stored by HHSL. You may also be entitled to request a copy of your Personal Information in a structured, commonly used, and machine-readable format or request us to transfer this information to another service provider.

Data Correction

Review, modify and correct your Personal Information. If you have a Customer Account, you may do this by logging into your online account at any time.

Marketing Communications

Unsubscribe from receiving marketing communications such as emails, newsletters, and other commercial electronic messages (“CEMs”) from HHSL.

You may select the unsubscribe link at the bottom of the email, responding to any SMS with “STOPHH”, or by logging into your online account and updating your Communication Preferences.

If you unsubscribe from receiving CEMs, you may still receive non-promotional communication related to the ongoing Customer Relationship.

To exercise any of the abovementioned privacy rights, please refer to the CONTACT US section. Your privacy rights are subject to certain restrictions and limitations. HHSL will take reasonable steps to verify your identity before fulfilling any such request. If your request is rejected, HHSL will notify you of the reason(s) and of any recourse available to you.

HHSL may update this Policy from time to time. Any changes will become effective when we post the modified version of the Policy on this webpage. We recommend you periodically review this Policy as it is your obligation to read, understand, and agree to the latest version.

The Last Updated date at the top of the Policy indicates when it was last updated.