TYPE OF INFORMATION COLLECTED
We may collect and maintain different types of personal information in respect to individuals with whom we interact. This includes:
- contact and identification information, including but not limited to your name, address, telephone number, e-mail address, physical address, date of birth, and gender;
- personal information in connection with your request for certain products, services, or information that you seek from us;
- additional service-related information concerning the products or services that we provide to or receive from you;
- business relationship information, including information related to your agreements, preferences, policies, managers/advisors, suppliers, materials, feedback and information requested by or provided to you;
- market-related information concerning market trends and activities impacting our business;
- information related to our media, investor and public relations activities; and
- information related to our interactions with financial and other advisors.
COLLECTION OF INFORMATION
In general, Citation collects personal information directly from you, with your knowledge and consent. Please note that video surveillance systems may collect some personal information when you attend our retail and other business locations. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism), or express. Implied consent is consent that can reasonably be inferred from your action or inaction. (For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement, and for any other purposes identified to you at the relevant time.) Express consent can be given orally, electronically, or in writing.
In most other circumstances where personal information that we collect about you is held by a third party, we will attempt to obtain your permission before we seek this information from such sources (such permission may be given directly by you or implied from your actions).
From time to time we may utilize the services of third parties and may receive personal information collected by those third parties in the course of doing business. When this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
REASONS FOR COLLECTING INFORMATION
Citation collects personal information to enable us to manage, maintain, and develop our business operations, including the following examples:
- to establish, maintain and effectively manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
- to enable you to register and access an account or service with us;
- to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;
- to facilitate the review of products and services that we obtain from you so that we may work with you, and so that you may understand our requirements for such products and services;
- to comply with your requests (for example, if you prefer to be contacted at a business or personal telephone number and advise us of your preference, we will use this information to contact you at that number);
- to protect us against error, fraud, theft, and damage to our goods and property;
- to enable us to comply with applicable law or regulatory process; and
- any other reasonable purpose to which you consent.
Collection of personal information via our video surveillance systems is done:
- to facilitate a safe and secure environment;
- to support an immediate response to an observed or reported safety incident;
- to help us collect certain demographic information (such as age and gender) in order to better understand who our customers are;
- to enable us to know how many customers we have, the manner in which they shop, and their specific shopping preferences;
- to protect us against error, fraud, theft, and damage to our goods and property (such as integration of point-of-sale transactional data with videos taken at the time of those transactions); and
- to enable us to comply with any and all applicable laws.
PRIVACY AND OUR EMPLOYEES
We train all employees on the importance of privacy. We give access to information about consumers only to those employees who require it to perform their jobs effectively.
We make access to sensitive personal information subject to rigorous procedural and technological controls, consistent with legal requirements and the specific demands of our business and appropriate customer service.
DISCLOSURE TO THIRD PARTIES
We will only provide personally-identifiable information about consumers to third parties if we are compelled to do so by order of a duly-empowered governmental authority, if we have the express permission of that consumer, or if it is necessary to process transactions and/or provide specific services.
PRIVACY AND OUR BUSINESS PARTNERS