Privacy Policy

This Privacy Policy outlines the privacy practices of Wolseley Canada Inc., its subsidiaries and affiliates (“Wolseley Canada”) concerning the collection, use, retention, disclosure and security of personal information obtained with respect to its customers, including credit applicants (sometimes hereinafter referred to as “you” or “your”) in Canada in connection with our business and has been developed to comply with Canada’s Personal Information Protection and Electronic Documents Act ("PIPEDA").

Protecting customer privacy is important, and Wolseley Canada is committed to maintaining personal information that it obtains about its customers secure and confidential.  Wolseley Canada uses personal information to provide you with the products and services that you have requested, and to get to know you, your needs and your preferences in order to provide you with superior customer service. 

Personal Information We Collect
In order to conduct certain aspects of our business, including processing your requests for our products or services, we may be required to collect personal information about you.  PIPEDA defines “personal information” is any information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. 

Accordingly, when used in this Privacy Policy, references to “personal information” include, but are not limited to:
• the e-mail address and other non-excluded identifying information regarding an individual in his or her capacity as an employee of an organization and the name, address, telephone number, e-mail address and other contact information of an individual outside of his or her role as an employee of an organization;
• information we collect to comply with applicable legal and regulatory requirements, including information about an individual’s business or occupation;
• social insurance number and/or other personal identifiers, such as date of birth, collected for credit checks;
• individual credit reports and credit history, asset and liability information;
• information about an individual’s past dealings and accounts with Wolseley Canada, including payment history or reports of suspicious transactions;
• information about past financial dealings with third party references provided to us;
• account information and records collected and retained over the course of an individual’s relationship with us; and
• such other personal information collected with an individual’s consent or as permitted or required by law.

Please note that you are never required to provide us with your social insurance number; however, in order to accurately process a credit application received from you, we require a social insurance number, date of birth or driver’s license number.


Collection of Personal Information
Wolseley Canada and its representatives may collect personal information in a number of circumstances in connection with our business and we may collect or receive personal information through a number of other sources, including:
• when you request a quote, order, purchase, return or exchange any of our products or services;
• when you submit a credit application, whether personally or on behalf of a corporate credit application, including in the capacity as a guarantor of the obligations of a corporate customer;
• when you correspond with us, including electronically, to contact one of our representatives, provide us with questions or comments or participate in any promotion or survey which we may make available from time to time;
• when we receive corporate information from existing or prospective customers in order to evaluate potential business relationships;
• when we access publicly available registries and databases to learn more about existing and potential customers;
• from credit reporting agencies and current and past creditors;
• from third party financial institutions and similar references provided in connection with a credit evaluation;
• through our research on industry sectors and other areas relevant to our business;
• from our affiliates with whom you may have had past dealings;
• when you visit or use any Wolseley Canada website, which may involve the collection of: (a) visitor data provided voluntarily by site users; and (b) site data that is collected automatically by our systems to provide us with information about site use and for research analysis purposes;
• when you apply for employment with Wolseley Canada; and
• other ongoing transactions or interactions with us, such as .


Use of Personal Information
Personal information will be used only for those purposes to which the affected individual has consented, subject to certain exceptions detailed below, as permitted by PIPEDA.

Wolseley Canada may use personal information with the affected individual’s consent in connection with credit decision-making, account opening processes and the ongoing administration of our business, including for such purposes as:
• indentify our customers, including the identifies of directors, officers and guarantors of corporate customers;
• developing and maintaining our relationship with you, including with respect to the promotion or offering of additional products and services that might benefit or be of interest to you, processing orders, providing ongoing service and arranging delivery of products or services;
• reviewing individual and corporate credit applications in furtherance of our credit approval process, including to make a determination of credit worthiness and whether to extend credit in response to credit requests;
• to obtain and exchange credit information from and with credit reporting agencies, credit references and other sources with whom you have or may expect to have financial dealings;
• meeting risk management and fraud and suspicious transaction monitoring, detection and prevention requirements;
• checking an individual’s past dealings or accounts with us or our affiliates;
• otherwise meeting legal and regulatory requirements;
• enforcing accounts and collecting any amounts owing to us;
• in connection with audit requirements;
• maintaining business records for reasonable periods to meet legal and regulatory records retention requirements;
• the evaluation of an application for employment;
• generally managing and administering our business; and
• as otherwise consented to by an individual consent or as permitted or required by law.

Wolseley Canada may use personal information without the affected individual’s consent, where:
• we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
• an emergency exists that threatens an individual’s life, health or security;
• the information is for statistical study or research;
• the information is publicly available;
• the use is clearly in the affected individual’s interest, and consent is not available in a timely way;
• knowledge and consent would compromise the availability or accuracy of the information; or
• collection is required to investigate a breach of an agreement.

Disclosure and Transfer of Personal Information
Personal information will be disclosed to those Wolseley Canada employees, officers and directors that need to know the information for the purposes of their work, including as identified below.  We may otherwise disclose personal information with the affected individual’s consent as permitted or required by law.

• Services and Transactions: We may disclose personal information as necessary in connection with the transactions, products and services you have requested, including to third party suppliers in respect of the product warranties offered to you.

• Disclosure within Wolseley:  Certain personal information about individual representatives of our corporate customers (including officers, directors, shareholders, owners, principals and guarantors) may be disclosed to our affiliates for the purposes of our and their ongoing risk management, fraud detection and security requirements, and for identity, financial and related background verification in connection with the provision of products and services.

• Service Providers:  We may use agents and service providers (including computer technology and financial service providers such as credit card issuers, credit reporting agencies, and those of our affiliates acting in such capacities) to collect, use, store and/or process personal information on our behalf, and personal information may be transferred to those entities for the purposes described in this Privacy Policy.

 Business Transactions:  Personal information may be used by Wolseley Canada and disclosed to parties connected with certain business transactions, such as the proposed or actual financing, insuring, sale or amalgamation of all or part of Wolseley Canada or our business or assets, and for the purposes of evaluating and/or performing a proposed transaction.  These purposes may include permitting parties such as lenders, insurers or purchasers to determine whether to proceed or continue with a proposed transaction, fulfilling reporting, inspection or audit obligations to those parties and disclosing personal information as part of concluding a purchase or sale.  Assignees or successors of Wolseley Canada or our business or assets may use and disclose personal information for similar purposes as those described in this Privacy Policy.

• Internal Processes:  We may disclose personal information as reasonably necessary to meet insurance, audit, processing and regulatory requirements.

Personal information disclosed to third parties will be protected by a confidentiality, non-disclosure or other similar agreement requiring appropriate privacy protection.

PIPEDA permits Wolseley Canada to disclose personal information to third parties, without the affected individual’s knowledge and consent, to:
• a lawyer representing Wolseley Canada;
• collect a debt owed to Wolseley Canada by the affected individual or customer with respect to whom the affected individual’s personal information was collected;
• comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
• a law enforcement agency in the process of a civil or criminal investigation; or
• a government agency or department requesting the information.

PIPEDA also permits Wolseley Canada to transfer personal information to a third party without the affected individual’s knowledge or consent if the transfer is simply for processing purposes and the third party only uses the information for the purposes for which it was transferred. 

Wolseley Canada will ensure, by contractual or other means, that third parties to who personal information is disclosed or transferred protects the personal information in accordance with this Privacy Policy and uses it only for the purposes for which it was disclosed or transferred.  Your personal information will never be traded, rented or sold to any third party without your consent.

Disclosure and Transfers Outside of Canada
Some of the third parties to whom we may disclose or transfer personal information, including our affiliates, may be located outside of Canada, and personal information may therefore be disclosed, transferred, stored (including electronically) or processed outside of Canada for the purposes described herein. 

Accordingly, any personal information which is disclosed, transferred, stored or processed outside of Canada may be subject to legal requirements in foreign countries applicable to Wolseley Canada or the third parties, including the United States USA PATRIOT Act of 2001, which facilitates, among other things, the ability of United States authorities to conduct searches and to seize or compel the disclosure of records which may contain personal information.

Consent
An individual’s express, written consent will be obtained before or at the time of collecting personal information and the purposes for the collection, use or disclosure of the personal information will be provided to the individual at the time of seeking his or her consent. Once consent is obtained from the individual to use his or her information for those purposes, Wolseley Canada has the implied consent of the affected individual to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified.

By signing a credit application and/or other form, implied consent is granted by the individual to obtain and/or to verify information from third parties such as banks, credit bureaus and other lenders in the process of assessing the credit worthiness of an individual or a corporate customer on whose behalf the individual’s personal information is collected.

An individual can choose not to provide some or all of the personal information at any time, but if Wolseley Canada is unable to collect sufficient information to proceed with the approval of a request for credit, such request may be delayed or turned down.

A customer or an individual can withdraw consent to the use of his or her personal information at any time by making such request in writing to Wolseley Canada.

This Privacy Policy does not cover statistical data from which the identity of individuals cannot be determined. Wolseley Canada retains the right to use and disclose statistical data as it determines appropriate.

Retention of Personal Information
Personal information will be retained in customer files as long as the file is active and for such periods of time as may be prescribed by applicable laws and regulations.

For example, a credit file will be deemed inactive if an application for credit is rejected, when financial obligations are repaid in full or when a guarantee is terminated. Information contained in an inactive file will be retained for a period of seven (7) years, except in the case where an application is rejected; in which case the personal information contained in the file will be retained for a period of up to two (2) years.

Accuracy
Wolseley Canada endeavours to ensure that any personal information provided by the individual in his or her active file(s) is accurate, current and complete as is necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed. Individuals are requested to notify Wolseley Canada of any change in personal or business information collected by Wolseley Canada.  Information contained in inactive files is not updated.

Safeguards
Wolseley Canada will use physical, organizational, and technological measures to safeguard personal information to only those Wolseley Canada employees or third parties who need to know this information for the purposes set out in this Privacy Policy.  This includes limiting access to those employees who need to know such information (for example, those who have to make a determination as to a customer’s eligibility for credit); storing files in filing cabinets when not in use and restricting access to work areas where active files may be in use; shredding files prior to disposal to prevent inadvertent disclosure to unauthorized persons; and restricting access to Wolseley Canada computers that contain personal information in electronic databases or other formats through password protection and internal Wolseley Canada security policies.

Questions, Requests for Access and Complaints
Any questions regarding this or any other privacy policy of Wolseley Canada may be directed to the Chief Privacy Officer.  Requests for access to information or complaints must be made in writing and sent to the Chief Privacy Officer at the address below:

Wolseley Canada Inc.
Attn: Chief Privacy Officer                             Email address: privacy@wolseleyinc.ca
880 Laurentian Drive
Burlington, Ontario  L7N 3V6
Telephone: (905) 335-7373

Requests for access will be fulfilled within 30 days and individuals will be informed of the existence, use and disclosure of his or her personal information.  If upon receiving access, you find that the information held by Wolseley Canada is inaccurate or incomplete, upon providing documentary evidence to verify the correct information, Wolseley Canada will promptly make the required changes to the personal information retained by it; provided, however, that you may be asked to provide identification and/or other proof acceptable to Wolseley Canada to verify such inaccuracies or changes.

Recourse
If an individual has a concern about the personal information handling practices of Wolseley Canada, a complaint, in writing, may be directed to the Wolseley Canada Chief Privacy Officer.  Upon verification of the individual’s identity, the Wolseley Canada Chief Privacy Officer will act promptly to investigate the complaint and respond to the individual within 60 days.

Where the Wolseley Canada Chief Privacy Officer makes a determination that the individual’s complaint is well founded, the Chief Privacy Officer will take the necessary steps to correct the offending information handling practise and/or revise the privacy policies and procedures of Wolseley Canada. Where the Wolseley Canada Chief Privacy Officer determines that an individual’s complaint is not well founded, the individual will be notified in writing of such determination.

If the individual is dissatisfied with the finding of and corresponding action taken by the Wolseley Canada Chief Privacy Officer, the individual may bring a complaint to the Federal Privacy Commissioner at the address below:

The Privacy Commissioner of Canada                     Website: www.privcom.gc.ca
112 Kent Street, Ottawa,
Ontario K1A 1H3
Telephone: 1-800-282-1376

Amendments to Privacy Policy
This version of the Wolseley Canada Privacy Policy is in effect January 1, 2014. This Privacy Policy is subject to amendment in response to developments in PIPEDA or other applicable privacy legislation and the Chief Privacy Officer will review and revise this Privacy Policy from time to time as required by such changes in privacy law. Notification of any changes in the Privacy Policy will be posted on the website of Wolseley Canada. Any changes in this Privacy Policy will apply to personal information collected from the date of the posting of such revised Privacy Policy.
     

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