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1. FreyWille (Canada) Inc. (“FreyWille”) is committed to maintaining the security and privacy of your personal information, including the information collected through its website [website URL] (“the Site”). This Policy documents our on-going commitment to you and has been developed in compliance with applicable laws, including the British Columbia Personal Information Protection Act (“PIPA”).  By accessing and using our Site, you consent to our Privacy Policy, our Terms and Conditions of Use and our collection, use and sharing of your information and data, and other activities, as described below. 

2. This Policy applies to personal information of individuals and does not cover information about corporate or commercial entities who are our suppliers or customers. Commercial information may be subject to protection under other policies and practices and through contractual arrangements, including confidentiality agreements.


3. This Policy does not impose any limits on the collection, use or disclosure of the following information by FreyWille:

(a) your business contact information; or
(b) publicly available information recognized under PIPA.


4. FreyWille is accountable and responsible for personal information under its control.


5. FreyWille has designated a Privacy Officer who is accountable for FreyWille’s compliance with this policy.


6. FreyWille will adopt procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding privacy policies and procedures and communicate policies and procedures to you.


7. FreyWille does not sell your personal information to any third party.


8.  FreyWille may share your personal information with its subsidiaries and affiliates.  FreyWille also reserves the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of FreyWille’s interests and/or assets or other corporate change, including, during the course of any due diligence process. 


2. FreyWille has certain affiliates, subsidiaries or entities that are related to FreyWille (together with FreyWille, referred to as the “Corporate Group”) who share a common vision to work together to maximize customer satisfaction and improve products and services. To meet these objectives, FreyWille shares your personal information with the Corporate Group for the following purposes:

(a) to determine which products and services of the Corporate Group may meet your potential needs;
(b) to share such information within the Corporate Group to improve the products and services, internal programs and operations of the Corporate Group and for internal statistical analysis purposes;
(c) to customize and optimize the websites and any promotional campaigns of the Corporate Group in accordance with your interests;
(d) to provide you with information, updates about new products, special offers, updates or other information relating to the business of the Corporate Group;
(e) to protect the Corporate Group, yourself and others from fraud and error and to safeguard the financial interests of the Corporate Group;
(f) to authenticate your identity;
(g) to contact you for market research or promotional purposes (which may be by e-mail, phone and/or mail);
(h) to collect debts owed to FreyWille;
(i) to manage or transfer assets or liabilities of FreyWille, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a carrier;
(j) to comply with legal and regulatory requirements.
The purposes listed above are a reasonably necessary part of your relationship with FreyWille. When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by PIPA or other law.


9.  To the fullest extent permitted by applicable law, FreyWille may also disclose your information if it believes in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of FreyWille or third parties (including through the enforcement of this Privacy Policy, our Terms and Conditions of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders).  To the fullest extent permitted by applicable law, FreyWille has complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you. 


10. FreyWille will obtain your consent to collect, use or disclose personal information except where FreyWille is authorized or required by PIPA or other law to do so without consent. Your consent may be express or implied, or given through your authorized representative. Consent may be provided orally, in writing, electronically, through inaction or otherwise. You may withdraw your consent at any time, subject to legal or contractual restrictions, provided reasonable written notice of withdrawal of consent is given by you to FreyWille. Upon receipt of your written notice, FreyWille will inform you of the likely consequences of the withdrawal, which may include the inability of FreyWille to provide certain products or services for which the delivery of that information is a prerequisite.


11.  In addition to any personal information or other information that you choose to submit to us via the Site, FreyWille and its third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with the Site.  To the extent that FreyWille associates Usage Information with your personal information that FreyWille collects directly from you on the Site, FreyWille will treat it as personal information. 

This Usage Information may include:

  • your IP address, UDID or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and FreyWille’s computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware, mobile network information);
  • the URL that referred you to the Site;
  • the areas within our Site that you visit and your activities there, including remembering you and your preferences;
  • your Device location;
  • your Device characteristics; and
  • certain other Device data, including the time of day, among other information. 

Tracking Technologies.  FreyWille may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, cookies, web beacons and embedded scripts.


Tracking Technologies Usage.  FreyWille may use Tracking Technologies for a variety of purposes, including:


Strictly Necessary.  FreyWille may use cookies or other Tracking Technologies that its consider to be strictly necessary to allow you to use and access the Site, including cookies required to prevent fraudulent activity and improve security. 


Performance‑Related.  FreyWille may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of its analytic practices or otherwise to improve the content, products or services offered through the Site. 


Functionality‑Related.  FreyWille may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you sign‑in to the Site or keeping track of our specified preferences, including in terms of the presentation of content on the Site. 


Targeting‑Related.  FreyWille may use Tracking Technologies to deliver content relevant to your interests on the Site and third‑party sites based on how you interact with FreyWille’s content.  This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.


12. FreyWille will not collect personal information indiscriminately and will limit its collection of your personal information to the collection activities described above and to what is reasonably necessary to provide a product or service and which is reasonably necessary for the purposes consented to by you. FreyWille may also collect information as authorized by PIPA or other law.


13. Your personal information will only be used or disclosed for the purposes set out above and as authorized by PIPA and other law. FreyWille will keep personal information used to make a decision affecting an individual for at least one year after using it to make the decision. FreyWille will destroy, erase or make anonymous, documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. FreyWille will take due care when destroying personal information so as to prevent unauthorized access to such information.


14. FreyWille will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. FreyWille will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate. If you notify FreyWille of the inaccuracy or incompleteness of personal information, FreyWille will amend the information as required. If appropriate, FreyWille will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, FreyWille will annotate the personal information under its control with a note that a correction was requested but not made.


15. FreyWille makes efforts to protect the personal information in its custody or control by making reasonable security arrangements intended to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. You should be aware that confidentiality and security are not assured when information is transmitted through e-mail or wireless communication. FreyWille will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when information is transmitted by e-mail or wireless communication.


16. You have a right to access your personal information held by FreyWille. Upon written request and authentication of identity, FreyWille will provide you with personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom such information has been disclosed. FreyWille may charge a reasonable fee for providing personal information in response to a personal information access request and will provide an estimate of any such fee upon receiving a written access to personal information request. FreyWille may require a deposit for all or part of the fee. FreyWille will make personal information available within 30 days or provide written notice where additional time is required to fulfill the request. In some situations, FreyWille may not be able to provide access to certain personal information. FreyWille may also be prevented by law from providing access to certain personal information. Where an access request is refused in whole or in part, FreyWille will notify you in writing, giving the reason for refusal and outlining further steps which are available to you.


17.  FreyWille understands the importance of protecting children’s privacy in the interactive world.  FreyWille does not use the Site to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. 


In the event that FreyWille becomes aware that it has collected personal information from any child, it will dispose of that information in accordance with COPPA and other applicable laws and regulations.  If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact FreyWille at [privacy officer email address]. 


18.  The Site may contain content that is supplied by a third party, and those third parties may collect your personal information when pages from the Site are served to you.  In addition, when you are on the Site you may be directed to other services that are operated and controlled by third parties that FreyWille does not control.  FreyWille is not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with FreyWille and/or others.  For example, if you “click” on a link, the “click” may take you off the Site onto a different site.  These other sites may associate their Tracking Technologies with you, independently collect data about you, including personal information, and may or may not have their own published privacy policies.  FreyWille encourages you to note when you leave the Site and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them. 


19. FreyWille may revise this Policy from time to time. The revised Policy will be posted on our website, and will come into effect 30 days after it is posted.


20. Complaints or questions regarding this Privacy Policy must be directed in writing to the Privacy Officer whose contact information is: 



511 Howe Street

BC V6C 2C2 Vancouver

phone: 1800 801 4094

e-mail: [email protected]



A list of all subsidaries of the FREY WILLE Group can be found here.