Last updated: August 03, 2023

Introduction

Unattended Markets Franchise Group Ltd. is committed to protecting your privacy (“UMI”, “we”, “our”, or “us”). This Privacy Policy describes the manner in which we and the franchisees who operate our self-service grocery stores (each, a “Store”) collect, use, and disclose your Personal Information (as defined below) in connection with your use of our website (aisle24.ca), mobile application, and the services available at our Stores. In this Privacy Policy we refer to the services we provide on and through our website, mobile application, and at each Store as the “Services”.

By accessing or using our Services, you signify that you have read, understood, and agree to  our collection, use, and disclosure of your Personal Information as described in this Privacy  Policy. You may withdraw your consent to our collection, use, or disclosure of your Personal  Information at any point by contacting our Privacy Officer using the contact information  provided in this Privacy Policy. Please note that if you withdraw your consent to our  collection, use, or disclosure of your Personal Information we may not be able to provide  you with all or part of the Services and you may not be able to use certain aspects of our  website or application.

This Privacy Policy forms part of our Terms of Service (the “Terms”) and is incorporated  into the Terms by reference. The Terms can be found here: https://aisle24.ca/terms conditions. 

Please click on the links available in the table of contents below to review the specific  sections of this Privacy Policy.

Contents of the Privacy Policy 

1. Changes to this Privacy Policy …………………………………………………………………………………………………………………… 2
2. What is Personal Information? ………………………………………………………………………………………………………………….. 2
3. What Personal Information do we collect about you? ………………………………………………………………………………. 2
4. When do we disclose your Personal Information? ……………………………………………………………………………………. 4
5. Storage and Transfer of your Personal Information………………………………………………………………………………….. 5
6. Retention of your Personal Information……………………………………………………………………………………………………. 5
7. Security of your Personal Information ……………………………………………………………………………………………………… 6
8. Access and control to your Personal Information……………………………………………………………………………………… 6
9. Cookies and collection of other non-personal information……………………………………………………………………….. 7
10. Children’s Privacy………………………………………………………………………………………………………………………………………. 8
11. Links to other websites …………………………………………………………………………………………………………………………….. 8
12. Contact us…………………………………………………………………………………………………………………………………………………. 8

1. Changes to this Privacy Policy 

We may update this Privacy Policy from time to time. We will notify you of any material  changes to this Privacy Policy by posting the updated version of this Privacy Policy on our  website. If required under applicable law, we will notify you via email of any updates prior  to the change becoming effective. The date of the most recent update of this Privacy Policy  appears at the top of this Privacy Policy. 

Please review this Privacy Policy periodically for any changes. Changes to this Privacy  Policy are effective when they are posted on this page.

2. What is Personal Information? 

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual (“Personal Information”). 

3. What Personal Information do we collect about you? 

We collect and maintain different types of Personal Information in respect of the individuals  with whom we interact. The Personal Information that we collect includes, but is not limited  to:

Contact and identification information, such as your name, address, postal code, telephone number, email address, birthdate, a copy of your government issued  identification, and IP address;

• Personal Information that is contained in any user content or feedback that you  create, submit, post, upload, publish, or otherwise make available to us on or  through our Services; 
• Personal Information that is contained on any accounts you have with third-parties  that you use in connection with the creation of your account with us to access or use  our Services (e.g. Google and Apple); 
• Personal Information on your device that you provide us with access to, such as your pictures and other information from your device’s camera and photo library; 
• Location information (e.g., GPS location of your device), demographic information, and movement data when you use our application or attend one of our Stores; 
• Biometric information based on your physical presence within our stores such as  information collected through facial recognition software and age verification  software; 
• Transaction information such as items purchased, date and time of your transaction,  amount purchased; and
• Personal Information collected by our in-store video or images with our use of  CCTV. 

When you sign up for our Services the payment information you provide is collected  directly by our third-party payment service providers. 

4. How do we collect your Personal Information?

As a general rule, we collect Personal Information directly from you, through your  interactions with us through our website, mobile application, and at our Stores. We may  also collect your Personal Information through Wi-Fi and Bluetooth functions and other  technology that connects with your mobile device, which enable us to detect the presence of  your and/or your device in our stores or provide operational insights. 

We also receive Personal Information from our franchisees that operate certain number of  our Stores and other third-parties who assist us with the operation of our business,  including our service providers that provide with information technology, security, and  building management services and solutions. In circumstances where Personal Information that we collect about you is received from a third-party, we will take reasonable steps to  ensure that such third-party has obtained your permission, either directly or implied, to  disclose your personal information to us.

5. Why do we collect your Personal Information? 

We collect and use Personal Information for the purposes identified at the time of  collection, as otherwise permitted or required by law, and for the following purposes: 

• To provide and maintain our Services: This includes providing you with our  Services, communicating with you in connection with our Services, and monitoring your use of our Services by visitors. 
• To manage your account: We will manage your registration as a user of our  Services. Once registered, the Personal Information you provide grants you access to  different functionalities of the Services that are available to you as a registered user. 
• To manage your requests: We will attend to and manage your requests to us. 
• To process and complete transactions: The development, compliance and  undertaking of the purchase contract for the products, items or services you have  purchased or of any other contract with us through the Services. 
• For Payment Processing: We will use third-party service providers to process  payments and transactions made through our application and at our Stores. That  information is provided directly to our third-party payment processors (e.g., Stripe,  FiServ (Clover), First Data, Chase Payment Tech, and Global Payment) whose use of  your Personal Information is governed by their privacy policies. We or our third party payment service provider may ask you to provide information to facilitate this  transaction and to verify your identity.
• To contact you: We may contact you by email, telephone calls, text messages, or  other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding transactional communicates, updates or informative  communications related to the functionalities, products, or contracted services,  including the security updates, when necessary or reasonable for their  implementation.
• To market to you: If we have received your opt-in consent or otherwise permitted  under applicable law to send you electronic marketing messages, we may use your  Personal Information to contact you with newsletters, marketing or promotional  materials, and other information that may be of interest to you, including news,  special offers, and general information about other goods, services, and events  which we offer that are similar to those that you have already purchased or inquired  about. You may opt-out of receiving any, or all, of these electronic marketing communications from us by using the unsubscribe link or instructions provided in  any email we send or by contacting us through our contact information provided  below. 
• To improve our Services: We may use your information to conduct analytics  geared towards improving and customizing our Services, such as data analysis,  identifying usage trends, determining the effectiveness of our promotional  campaigns, and to evaluate and improve our Services, products, marketing, and your  experience. 
• For business transfers: We may use your information to evaluate or conduct a  merger, divestiture, restructuring, reorganization, dissolution, or other sale or  transfer of some or all of our assets, whether as a going concern or as part of  bankruptcy, liquidation, or similar proceeding, in which Personal Information held  by us about our users is among the assets transferred. 
• For security: We may collect your information through cameras in our stores for  security, fraud, incident reporting, and loss-prevention purposes, or to collect  analytics and improve operations. 
• For research and development: We may aggregate information about your activities and Personal Information collected from you while using our services,  received from third-parties and collected through cookies and tracking technologies.  We only use the aggregate information internally for research and development and  to improve your customer experience. 
• For other purposes to which you consent: We may use your information for other reasonable purposes to which you consent.

6. When do we disclose your Personal Information? 

We may disclose your Personal Information in the following circumstances 

• With service providers: We may disclose your Personal Information with service  providers to perform Services on our behalf, including hosting service providers. These  third-parties are authorized to collect, store, use, process, and transfer information  about your activity on our Services in accordance with our Privacy Policy.
• For business transfers: We may disclose your Personal Information in connection  with, or during negotiations of, any merger, sale of our assets, financing, or acquisition  of all or a portion of our business to another company. We will provide notice before  your Personal Information is transferred and becomes subject to a different Privacy  Policy. 
• For internal purposes: We may disclose your Personal Information to our respective  employees, contractors, consultants, and other parties who require such information to  assist us with managing our relationship with you, including third-parties that provide  services to us. 
• With affiliates: We may disclose your information with our affiliates, in which case we  require those affiliates to honor this Privacy Policy. Affiliates include our parent  company and any other subsidiaries, joint venture partners, Franchisees or other  companies that we control or that are under common control with us. 
• To comply with our legal obligations: Under certain circumstances, we may be  required to disclose your Personal Information as permitted or required by applicable  law or regulatory requirements. 
• For our internal purposes: We may disclose your Personal Information under the  good faith belief that such action is necessary to protect and defend our rights or  property; prevent or investigate possible wrongdoing in connection with the Services;  protect the personal safety of users of the Services or the public; and to protect against  legal liability. 
• With your consent: We may disclose your Personal Information for any other reasonable purpose with your consent. 

7. Storage and Transfer of your Personal Information 

Your information, including Personal Information, is processed at our operating offices and  in any other places where the parties involved in the processing are located. It means that  this information may be transferred to and maintained on servers located outside of your  province, country, or other governmental jurisdiction where the data protection laws may  differ than those from your jurisdiction. This may mean that your information is transferred  to different jurisdictions and authorized officials of governments in those jurisdictions may  be lawfully able to access your Personal Information based on the laws of that country.

8. Retention of your Personal Information 

We will retain your Personal Information only for as long as is necessary for the purposes  set out in this Privacy Policy and to comply with our legal obligations, resolve disputes, and  enforce our legal agreements and policies. 

UMI may retain de-identified, anonymized, and aggregated information and may use this  information for, analytic, improvements, and research and development purposes in  connection with the Services and our business.

9. Security of your Personal Information 

The security of your Personal Information is important to us, we have implemented commercially reasonable physical, technical, and procedural safeguards based on the  sensitivity of the Personal Information we collect, use, and disclose. These safeguards are  designed to prevent your Personal Information from loss and unauthorized access,  collection, use, disclosure, copying, modification, disposal, or destruction. However, no  security system or method of transmission over the internet, or method of electronic  storage is 100% secure. While we strive to use commercially acceptable means to protect  your Personal Information, we cannot guarantee its absolute security.  

In the event that any information under our control is compromised as a result of a breach  of data security, we will take reasonable steps to investigate the situation and, where  appropriate, notify those individuals whose information may have been compromised and  take additional steps, in accordance with any applicable laws and regulations.  

10. Access and control to your Personal Information 

Accessing your Personal Information 

If you have any questions about the accuracy of the Personal Information that we have  collected about you, you can have access to that Personal Information in order to verify and  update it, unless we are permitted or required under applicable laws to refuse your access  to such Personal Information. You may contact us at the contact information provided  below to request access to Personal Information that we have about you.  

Controlling your Personal Information 

• Profile and settings: You may update your account information and adjust your  account settings by logging into your account. Please note that changes to your settings  may require some time to take effect. 
• Pictures and information from your device’s camera: You can update your  permissions on your advice under the “Settings” app on your device, to deny us access  to this information. 
• Email communication: You may choose to stop receiving promotional email  communications from us by clicking on the “unsubscribe link” provided in our email  communications. 
• Geolocation and device information: You may control our access to your device  information through your “Settings” app on your device. You may also control precise  location tracking by adjusting your location services settings on your mobile device. We  may continue to approximate your location based on your IP address or through other  means when you access our Services through a computer or device. 
• Google analytics: For information on how to opt out of Google collecting and using  your data for analytics, visit https://tools.google.com/dlpage/gaoptout.

Requests for deletion or amendment of your Personal Information 

Subject to our legal obligations to retain certain Personal Information, you may request the  amendment or deletion of your Personal Information at any time. Following an amendment  or deletion request, UMI will amend or delete your Personal Information, unless the  Personal Information must be maintained or retained due to legal or regulatory  requirements as described in this Privacy Policy. Send an email to our Privacy Officer using  the contact information provided in this Privacy Policy with your request for amending or deleting your account and Personal Information.  

11. Cookies and collection of other non-personal information 

Cookies 

We use cookies and similar tracking technologies. A cookie is a small file placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history, for the purpose of storing and tracking information about you. This  allows us to distinguish you from other users, track your activity on our Services and store  certain information. Cookies and similar technologies we use are designed to improve and  analyze our Services. The tracking technologies we use are beacons, tags, and scripts to  collect and track information, and to improve and analyze our Services.  

We may use the following cookies or tracking technologies: 

• Necessary / Essential Cookies: These Cookies are essential to provide you with  Services available through the website and to enable you to use some of its features. 
• Flash Cookies: These Cookies are used to collect and store information about your preferences or your activity on our Services. 
• Cookies Policy / Notice Acceptance Cookies: These Cookies identify if users have  accepted the use of cookies on the website. 
• Functionality Cookies: These Cookies allow us to remember choices you make  when use the website, such as remembering your login details or language preference. 
• Web Beacons: These are small electronic files that allow us to collect data for  analytic functions including, counting users who have visited those pages or opened  an email and for other related website statistics. 

Cookies can be “Persistent” or “Session” cookies. Persistent cookies remain on your  personal computer or mobile device when you go offline, while Session cookies are deleted  as soon as you close your web browser. 

You can modify your browser settings browser to refuse all cookies or to indicate when a  cookie is being sent. However, if you decline the use of cookies, you may not be able to use  parts of our Service. Unless you have adjusted your browser settings. For more information  about the cookies we use and your choices regarding cookies, please visit our “Controlling  your Personal Information” or our Cookies Policy.

Other information that we collect 

We may also collect information related to your visit to our mobile application and Stores,  including the device domain used to access our Services, the operating system on your  device, your device settings, application IDs, unique device identifier, mobile operating  system, the type, and version of your browser, crash data, other unique device identifiers,  the website that redirected you to access our Services, the page of our Services you entered  and exited at, and time spent, any page within our Services that is viewed by you, what  country you are from, and other diagnostic data your browser sends whenever you visit access or use our Services or when you access or use the Services by or through a mobile  device.

12. Children’s Privacy 

Our Services are not intended for anyone under the age of 18. We do not knowingly collect  Personal Information from anyone under the age of 18. If you are a parent or guardian and  you are aware that your child has provided us with Personal Information, please contact our  Privacy Officer. If we become aware that we have collected Personal Information from  anyone under the age of 18 without verification of parental consent, we will take reasonable  steps to remove that information from our servers.

13. Links to other websites 

Our Services may contain links to other websites that are not operated by us. These links  are provided for your convenience only and you assume all risk for clicking these links to  other websites. We cannot assume any responsibility or liability for the content, privacy  practices, policies, or actions of the third-parties that operate these websites and will not be  responsible for how Personal Information is collected, used, or disclosed by the third-party.  We strongly advise you to review the applicable Privacy Policy of every site you visit.

14. Contact us 

If you have any questions about this Privacy Policy or concerns about how we manage your Personal Information, please contact our Privacy Officer by telephone, in writing or by e mail. If you have any questions about this Privacy Policy, you can contact us at: Privacy@aisle24.com.