Where is personal information stored and processed?

Our employees involved in data processing, and our servers are based in Columbus, Ohio, US, and other locations throughout Canada. We work with affiliated and unaffiliated service providers in Canada, India, China, and other jurisdictions around the world. This means that personal information will be communicated outside of Canada or your province (including, for residents of Quebec, outside Quebec) to locations throughout the U.S. and other countries where we or our service providers access or store your personal information. Also, the governmental bodies that have jurisdiction in that instance (e.g., courts and law enforcement agencies) may be entitled to access your personal information in accordance with the laws of those jurisdictions.

 

We protect personal information?

We maintain administrative, technical, and physical safeguards designed to protect the personal information that we collect through our Services against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.

Our administrative safeguards include implementing, maintaining, and training employees on company privacy and information security policies and procedures. Our physical and technical safeguards include maintaining physical security policies and standards to protect company systems and data, and a cybersecurity program overseen by our executive leadership team.

We limit access to personal information on a need-to-know basis, and our associates are advised of the importance of confidentiality. The categories of our associates who have such access to your personal information include those responsible for (1) accounting, auditing, & reporting; (2) advertising; (3) analytics; (4) claims management; (5) customer service; (6) fraud monitoring and prevention; (7) human resources (e.g., for applications, payroll, and benefits); (8) information security; (9) logistics (e.g., for order processing, fulfillment, and shipping); (10) payment and transaction processing; (11) product and services development (e.g., for focus-group administration); (12) shopping and customer engagements (e.g., events, contests, sweepstakes, and loyalty programs); (13) surveys; and (14) technology administration and integrity.