Privacy Policy

This Privacy Policy describes the purposes for which and the manner in which Metal Supermarkets IP Inc. (Metal Supermarkets) collects, uses, maintains and discloses personal data or information collected from users of this Website. It also describes procedures available for users who have questions, complaints or disputes relating to Metal Supermarket’s handling of their personal data. Metal Supermarkets adheres to the Safe Harbor requirements published by the United States Department of Commerce, including the Safe Harbor Privacy Principles. Accordingly, Metal Supermarket’s Privacy Policy and procedures for handling personal data are adequate for purposes of receiving personal data transfers from the European Union in compliance with Directive 95/46/EC of the European Parliament and of the Council of October 24, 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the EU Directive). However, users should understand that adherence to the Safe Harbor Privacy Principles may be limited to the extent necessary to meet national security, public interest, law enforcement requirements, judicial process or if the effect of the EU Directive or of Member State law is to allow exceptions or derogations, provided such exceptions or derogations are applied in comparable contexts.

The Information Metal Supermarkets Collects

Metal Supermarkets gathers personal data from users of its website to improve the content on the website, to facilitate sales and order inquires and to enhance a User’s online experience, and for other business purposes. Metal Supermarkets takes reasonable precautions to secure a User’s personal data. Metal Supermarkets uses reasonable technical solutions to make a User’s visit to this website as safe as it can reasonably be, but users should understand that no information system can ever be made 100% secure. Metal Supermarkets may collect various types of personal data voluntarily provided by users, including name, company name, address, telephone number, credit card number or other billing information, e-mail address, and other information such as survey responses. Metal Supermarkets may also collect information about how users use this website, for example, by tracking the number of unique views received by the pages of the website or the domains from which users originate. Metal Supermarkets may use “cookies” to track how users use this website. A cookie is a small pieces of data stored on a computer and delivered through a Web browser. Most, if not all, commercial websites now use cookies. By using this technology, Metal Supermarkets can provide a user with an enhanced online experience. It is possible for a user to turn off cookies in a Web browser. If a user does this, the user can still browse Metal Supermarket’s website, but Metal Supermarkets will not be able to provide the user with a more personalized experience.

Metal Supermarkets collects from users only personal data that is relevant to the purposes outlined above. Metal Supermarkets takes reasonable steps to ensure that the personal data that it collects is reliable, accurate, and complete.

How Metal Supermarkets Uses Information

Metal Supermarkets may use personal data collected through its website to contact users regarding products and services offered by Metal Supermarkets and its affiliates, independent contractors and business partners, and otherwise to enhance a user’s experience with Metal Supermarkets and such affiliates, independent contractors and business partners. Metal Supermarkets may also use information collected through its website for research regarding the effectiveness of the website and the marketing, advertising and sales efforts of Metal Supermarkets, its affiliates, independent contractors and business partners.

Opt Out Procedure

Users have the choice to opt out of having their personal information used by Metal Supermarkets for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual. When a user is first asked to provide personal data or information to Metal Supermarkets, or as soon thereafter as is practical, but in any event before Metal Supermarkets uses such information for a purpose other than that for which it was originally collected or processed by Metal Supermarkets, Metal Supermarkets will provide a user with clear and conspicuous, readily available, and affordable mechanisms to exercise this choice.

Retargeting

Metal Supermarkets collects data about your activities that does not personally or directly identify you when you visit our website, or the websites and online services where we display advertisements (“Publishers”). This information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. We use the information we collect to serve you more relevant advertisements (referred to as “Retargeting”). We collect information about where you saw the ads we serve you and what ads you clicked on.

We do not target ads to you based on sensitive personal data, such as information related to race or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, trade union membership, physical or mental health or condition or sexual life. Any data used to serve targeted advertisements is de-identified and is not used to personally or directly identify you.

Disclosure of Information

Metal Supermarkets may disclose personal data or information collected from users to third parties acting as Metal Supermarket’s agents to perform tasks on behalf of and under the instructions of Metal Supermarkets. Metal Supermarkets will not disclose personal data or information collected from users to any other third party aside from its agents. The third party agents include affiliates, independent contractors and business partners who will use the information for the purposes outlined above. Metal Supermarkets may also disclose aggregated data based on information collected from users to investors in Metal Supermarkets and potential partners. Finally, Metal Supermarkets may transfer information collected from users in connection with a sale of Metal Supermarket’s business. Before Metal Supermarkets discloses personal data of a User to a third party agent, Metal Supermarkets will either: (a) ascertain that the agent subscribes to the Privacy Principles, (b) determine that the agent is subject to the EU Directive, (c) determine that the agent is subject to another adequacy finding or (d) enter into a written agreement with the agent requiring that the agent provide at least the same level of privacy protection as is required by the relevant Safe Harbor Privacy Principles.

Enforcement

To enforce the requirements of the Safe Harbor and to provide an independent means of resolving disputes, Metal Supermarkets has voluntarily elected to subject itself to the European Data Protection Authorities. In addition, Metal Supermarkets performs periodic self-assessments to verify that it is adhering to the Safe Harbor Privacy Principles and that the provisions of this Privacy Policy are true and accurate, fully implemented and followed by Metal Supermarkets.

Questions, Complaints and Disputes

If a User has any questions, complaints, or disputes with Metal Supermarkets with respect to the organization’s handling of personal data, a User may notify Metal Supermarkets by sending an email to Support@metalsupermarkets.com. Metal Supermarkets may modify this Privacy Policy at any time without prior notice to Metal Supermarket’s users or the public.

Privacy policy (For Users with European Economic Area based IP Addresses)

1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we determine the purposes and means of the processing of personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, if your IP address is based in the European Economic Area, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, “we”, “us” and “our” refer to MSKS IP Inc. For more information about us, see Section 13.

2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include specify data. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

3.7 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.

3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

3.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.11 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.12 Please do not supply any other person’s personal data to us unless we prompt you to do so.

4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 Financial transactions relating to our website and services are OR may be handled by our payment services providers, identify PSPs. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at URLs.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 We and our other group companies have offices and facilities in Canada specify countries. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of Canada.

5.3 The hosting facilities for our website are situated in Canada. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries.

5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:
(a) personal data category or categoris will be retained for a minimum period of period following date, and for a maximum period of period following date.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data category will be determined based on specify criteria.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.11 You may exercise any of your rights in relation to your personal data by written notice to us.

9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;
(b) status – we use cookies to help us to determine if you are logged into our website;
(c) personalization – we use cookies to store information about your preferences and to personalise the website for you;
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you;
(f) analysis – we use cookies to help us to analyse the use and performance of our website and services; and
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details
13.1 This website is owned and operated by MSKS IP INC.

13.2 We are registered in CANADA under MSKS IP INC, and our registered office is at 520 Abilene Drive, 2nd Floor, Mississauga, ON L5T 2H7.

13.3 You can contact us:
(a) by post, to the postal address given above;
(b) or by email, using the email address published on our website from time to time or at contracts@metalsupermarkets.com.

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