Privacy Policy

C.G. Emery International Limited ("C.G. Emery", "we", "us" or "our") is a Canadian distributor and wholesaler of fishing and hunting equipment, gear and supplies. This Privacy Policy explains what personal information we collect through the website located at cgemery.xyz — including the fishing and hunting product sections, the dealer locator, the contact, warranty claim, Pro Staff and dealer application forms, the newsletter, product reviews and the password-protected dealer portal (together, the "Site") — how we use and share that information, and the choices available to you.

We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, including Quebec's Act respecting the protection of personal information in the private sector.

1. Who this policy applies to

This policy applies to visitors to the Site, to consumers who contact us or submit a warranty claim, review or application, and to the individuals who represent our dealers in the dealer portal. It does not apply to third-party websites we link to, or to information our employees provide as part of their employment, which is handled under our internal human resources policies.

Most of the business information we hold — company names, wholesale account numbers, order history and pricing — relates to businesses rather than to individuals and is not personal information. Where business records identify a person, such as the name, direct phone number or email address of a buyer at a dealership, we treat that information as personal information under this policy.

2. Personal information we collect

We collect only the personal information we need for the purposes described in this policy.

a) Information you give us

• Contact and general enquiries. Your first and last name, company name (if any), email address and the content of your message.
• Newsletter subscription. Your email address.
• Dealer account applications. The applicant's email address, and then business details including company and trade or legal name, street address, unit, city, province, postal code, phone and fax numbers, the name of the principal owner, years in business, the names of the buyer and accounts payable contact, your reason for applying, three trade references (company name, address and phone number for each), and the name and title of the person completing the application.
• Dealer portal accounts. Account holder name, email address, encrypted password, language preference, and — if you enable them — two-factor authentication settings and recovery codes and API tokens. We never store your password in readable form.
• Orders placed in the dealer portal. Order lines, quantities, shipping and billing details, invoices, statements and purchase history associated with your dealer account.
• Warranty claims. Your full name, email address, phone number, and your address, city, postal code and country where provided; the product name, serial number and variant; the date, place and channel of purchase and any store, show or online retailer details; an order or receipt number; the receipt or proof of purchase file you upload; photographs of the product (up to five); and your description of the problem, when it began and any repair you attempted.
• Pro Staff and Brand Ambassador applications. Your name, email address, age, gender, city, province and telephone number, together with the species you pursue, your fishing or hunting style, your competition and sponsorship history, existing affiliations, social media handles, brands you use, and how you propose to promote our products.
• Product reviews. The name and location you choose to display, your email address, and your rating, heading and review text.

b) Information collected automatically

• Technical and usage data. Your IP address, browser type and settings, device and operating system, referring page, the pages you view and the dates and times of your visits, recorded in our server logs.
• Security and anti-spam data. The IP address and, where applicable, the email address associated with a form submission, retained so we can detect and block abusive or automated submissions. Every public form is protected by a hidden honeypot field, a simple arithmetic security check or Google reCAPTCHA, and rate limits.
• Cookies and similar technologies. See section 6.

c) Information from other sources

• Trade and credit references. When you apply for a dealer account or credit terms, we contact the references you give us and may obtain a commercial credit report about your business.
• Manufacturers, carriers and sales representatives. Information relating to your orders, deliveries or warranty claims may reach us from the manufacturer whose product is involved, from the carrier that delivered a shipment, or from our sales representatives.

We do not collect sensitive information through the Site. Please do not send us government identification numbers, health information or full payment card numbers through a form or by email. If credit card payment is arranged for your account, it is handled directly with our accounting department outside the Site.

3. Why we use your personal information

We use personal information for the following purposes:

• to answer your enquiries and provide customer and dealer support;
• to review dealer applications, verify references and creditworthiness, open and administer dealer accounts, and set payment and credit terms;
• to process, fulfil, ship, invoice and collect payment for orders, and to administer returns and credits;
• to receive, assess and process warranty claims, which includes forwarding the claim to the manufacturer of the product where their warranty program applies;
• to evaluate Pro Staff and Brand Ambassador applications and administer those relationships;
• to publish product reviews on the Site, and to contact you about a review you submitted;
• to send you our newsletter, new product announcements, program information and promotions where you have consented to receive them;
• to operate, maintain, secure and improve the Site, including troubleshooting, analytics, preventing fraud, spam and abuse, and enforcing our Terms of Service; and
• to meet legal, regulatory, tax and accounting obligations, and to establish or defend legal claims.

We do not sell your personal information, and we do not rent or trade our newsletter list. We do not use your personal information to make decisions about you based solely on automated processing.

4. Consent

We collect, use and disclose personal information with your consent, except where the law permits or requires us to act without it. By submitting a form on the Site you consent to our use of the information in it for the purpose the form serves. Consent may be express — for example, checking a box or subscribing to the newsletter — or implied by your voluntary provision of information for an obvious purpose, such as sending us a message so that we can reply.

You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice, by contacting us using the details in section 14. Withdrawing consent may mean we can no longer provide certain services, such as maintaining a dealer account or processing an open warranty claim.

5. When we share personal information

We share personal information only as described below. We never sell it.

• Service providers. Companies that perform services on our behalf, such as website and database hosting, email delivery, IT support and maintenance, analytics, spam and bot protection, payment processing and freight carriers. They may use the information only to provide the service to us and are required to protect it.
• Manufacturers and suppliers. Where a warranty claim, product recall, safety notice or technical support request must be handled by the manufacturer, we share the information needed to resolve it.
• Credit references and reporting agencies. In connection with a dealer credit application, and in connection with collection of a past-due account.
• Professional advisors. Our accountants, auditors, insurers and legal counsel, where necessary.
• Legal and safety. Where required or permitted by law, including in response to a subpoena, warrant, court order or other lawful request, to investigate suspected fraud, spam or abuse, or to protect the rights, property or safety of C.G. Emery, our customers or others.
• Business transactions. In connection with a merger, financing, reorganization or sale of all or part of our business, subject to appropriate confidentiality protections.
• Publicly on the Site. Product reviews you submit are published with the name and location you provide. Your email address is not published. Do not include anything in a review that you would not want made public.

6. Cookies and similar technologies

The Site uses a small number of cookies:

• Strictly necessary cookies. A session cookie and a cross-site request forgery (CSRF) token cookie that keep you signed in, protect forms from being submitted by third-party sites, and make the shopping and ordering functions of the dealer portal work. If you ask us to remember you, a "remember me" cookie keeps you signed in between visits.
• Preference cookies. A cookie named cge_locale remembers whether you are browsing the Site in English or French, for up to one year.
• Security cookies. Google reCAPTCHA sets cookies on pages that use it (currently the warranty claim forms) to tell human visitors from automated ones.
• Analytics. Where analytics are enabled, we use them in aggregate to understand how the Site is used and to improve it. We do not use analytics to build advertising profiles about you.

Most browsers let you refuse or delete cookies through their settings. Blocking strictly necessary cookies will prevent the dealer portal, and some forms, from working. The Site does not currently respond to browser "Do Not Track" signals, as there is no common standard for them.

7. Third-party services and links

The dealer locator uses Google Maps, and some forms use Google reCAPTCHA; both are provided by Google and are subject to Google's own privacy policy and terms. The Site also links to manufacturer websites and to online retailers where consumers can buy the products we distribute. We do not control those sites and are not responsible for their content or privacy practices. Review their policies before providing personal information to them.

8. Where your information is stored

Personal information collected through the Site is stored on servers operated for us and is accessible to our staff in Canada. Some of our service providers — for example email delivery, security and analytics providers — may process or store information outside Canada, including in the United States. While information is in another country, it is subject to that country's laws and may be accessible to its courts, law enforcement and national security authorities under those laws. We take reasonable steps, including contractual protections, to require our service providers to protect personal information in a manner consistent with this policy.

9. Commercial electronic messages

We send commercial electronic messages, such as new product announcements, program information and promotions, in accordance with Canada's Anti-Spam Legislation (CASL) and only where we have your consent or another permitted basis for doing so. Every commercial message includes an unsubscribe link, and you can also unsubscribe by writing to info@cgemery.com. We will still send you transactional messages about your account, orders, invoices and warranty claims.

10. How we protect personal information

We maintain physical, organizational and technical safeguards appropriate to the sensitivity of the information, including encrypted connections (HTTPS) across the Site, passwords stored using one-way hashing, optional two-factor authentication for dealer portal accounts, role-based access limited to staff who need the information to do their jobs, rate limiting, honeypot and CAPTCHA protection on public forms, IP blocking of abusive sources, and regular software updates and backups.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please choose a strong, unique password for your dealer portal account, keep it confidential, and notify us immediately at info@cgemery.com if you believe your account has been compromised.

11. How long we keep personal information

We keep personal information only as long as necessary to fulfil the purposes for which it was collected and to meet our legal, tax and accounting obligations. In general:

• enquiry and contact messages are kept while we handle the request and for a reasonable follow-up period;
• dealer account, order, invoice and payment records are kept for the life of the account and afterwards for the period required by Canadian tax and business records law;
• warranty claim records, including uploaded photographs and receipts, are kept for the duration of the applicable warranty program and any related dispute;
• newsletter subscriptions are kept until you unsubscribe, plus a short suppression record so we do not re-add you;
• spam and abuse records, including IP addresses and blocked addresses, are kept as long as needed to protect the Site; and
• server logs are kept for a limited period for security and troubleshooting.

When personal information is no longer needed, we delete it or render it anonymous.

12. Your rights and choices

Subject to limited legal exceptions, you may:

• Access the personal information we hold about you and be told how it has been used and to whom it has been disclosed;
• Correct information that is inaccurate or incomplete;
• Withdraw consent to a particular use, unsubscribe from our newsletter, or ask that a review you submitted be removed from the Site;
• Request deletion of information we no longer need to keep; and
• Complain about how we have handled your personal information.

Dealer portal users can view and update much of their own account information after signing in. For anything else, write to our Privacy Officer using the details in section 14. We may ask you to verify your identity before we act, and we will respond within 30 days. Access is generally free; if a request requires substantial effort we will tell you the estimated cost in advance and let you decide whether to proceed. If we refuse a request in whole or in part, we will explain why and tell you how to challenge the decision.

Residents of Quebec may also request that we stop disseminating personal information or de-index a link where dissemination contravenes the law or a court order, and may request that personal information you provided to us be released in a structured, commonly used technological format.

13. Children and minors

The Site is intended for adults and for business use, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us and we will delete it.

14. Contacting us and our Privacy Officer

Questions, access requests and complaints about privacy can be directed to our Privacy Officer:

Privacy Officer — C.G. Emery International Limited
165 Idema Road
Markham, Ontario L3R 1A9
Canada
info@cgemery.com
(905) 475-6700
Monday to Friday, 8:30 AM – 4:30 PM EST

We will acknowledge your complaint, investigate it and tell you the outcome. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada, or the privacy regulator in your province where one has jurisdiction.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The version posted on the Site is the version in effect, and the "Last updated" date at the top shows when it last changed. If we make a material change to how we use personal information already collected, we will take reasonable steps to notify you and, where required, obtain your consent.