Privacy Policy

 

What does this notice cover?

 

This notice describes how Restitution Brands LLC dba Terrapass, (“Terrapass”, “we“, “us” or “our“) processes your personal data. It also describes your data protection rights, including a right to object to some of the processing which Terrapass carries out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.

This notice applies to users of the Terrapass website. The data processing described in this notice may be limited as required by applicable law.

We may also provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.

 

What personal data we collect?

We collect the following information about you when you use the Terrapass website, purchase Terrapass products and services and communicate with us:

• information to identify you, such as your name, date of birth, billing address and contact details;
• information necessary to establish and access your Terrapass account, such as your username and password;
• information related to the browser or device you use to access our website;
• payment information, including billing address and confirmation of your card holder payment data, where you purchase our products or subscribe to our services;
• your marketing preferences including any consents you have given us;
• the content of communications you send us;

 

Why we collect, use and store this personal data?

We collect, use and store your personal data for the reasons set out below.

• To fulfil a contract, or take steps linked to a contract, that we have with you. This is relevant if you are an individual purchasing Terrapass products or services. It includes:
  • confirming payments have been made;
  • communicating with you about your contract with us; and
  • providing customer service.

• As required to conduct our business and pursue our legitimate interests, in particular:
  • we will use your information to provide the Terrapass products and services you have requested, and respond to any comments or complaints you may send us;
  • we monitor use of our website and use your information to help us monitor, improve and protect our services;
  • we use information you provide as well as information which we have collected about you to investigate any complaints received from you, or from others, about our website, products or services;
  • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation) and;
  • where you purchase our goods or subscribe to our services your payments will be handled by external providers who will provide us with data confirming your payments.

• Where you give us consent:
  • we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used
  • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

• For purposes which are required by law:
  • In response to requests by government or law enforcement authorities conducting an investigation.

Withdrawing consent or otherwise objecting to direct marketing

 

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.

 

How we share your personal data

 

Personal data will be shared with third party service providers, who will process it on our behalf for the purposes identified above. In particular, to help us store your details, manage your account and communicate with you.

We use PayPal as a payment services provider. Where you pay for our services through PayPal, it will act as a controller of your data. We recommend that you review PayPal’s privacy policy to understand how it will use your data, and how you can exercise your data subject rights for PayPal’s processing of your data.

In the event that Terrapass is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business. 

We will only transfer your data outside of the UK/ EEA to organizations in countries which are subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws (for example your data is collected directly by Restitution Brands LLC dba Terrapass, which is a commercial organization in Canada and therefore benefits from an adequacy decision) or where we have put into place appropriate measures (such as European Commission approved Standard Contractual Clauses or a supplier’s binding corporate rules).

 

Your choices and rights

 

You have certain rights in relation to the data we process about you. To exercise certain rights you can fill out the forms linked to below (alternatively, you can email  [email protected].)

You have the right to do the following:

 

• ask us for a copy of your personal data
• to delete your data
• to obtain the personal data you provide in a structured, machine readable format

Please identify yourself via e-mail

Enter your email address

Send an email to [email protected] in order to do any of the following:

• to correct your data
• to restrict processing of your personal data
• In addition, you can object to the processing
• To obtain a copy of any correspondence that you have sent to us

If you would like to exercise the above rights with respect to data that we process about you outside of the context of the website (for example, in the context of customer support) please contact us by [insert contact information, e.g. by using the email address in the Contract us section below].

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. For example, if you ask us to erase your data, we will not be able to delete data that we hold on back-up systems as this would compromise our ability to restore our services in the event of a disaster. In this case, we will restrict the processing of our data to what is needed to maintain our back-up systems. If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or believe a breach has taken place. In the UK this is the Information Commissioner’s Office; please click here for detail.

 

Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase from Terrapass or otherwise engage with Terrapass. All other provision of your information is optional.

 

How long we retain your personal data?

 

Where we process registration data, we do this for if you are an active customer of Terrapass and for 7 years after this.

Where we process personal data for marketing purposes or with your consent, we process the data for 3 years from when the consent was collected or until you ask us to stop (whichever is sooner). Should you ask us to stop we shall process our data for a short time afterwards to allow us to implement your requests. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Where we process personal data in connection with performing a contract, we keep the data for 7 years from the conclusion of the contract. 

 

Updates to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

Contact us

 

The data controller for your personal data will be Restitution Brands LLC dba Terrapass.

 

The EU representative for your personal data is:

The UK representative for your personal data is:

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please write to us at Terrapass Group Inc., Privacy Officer, 100 King Street West, Suite 2630, Toronto, ON M5X 1E1 Canada