Soghaat Privacy Policy

Soghaat is a business brand and has the Privacy Commitment complies with all
applicable federal and state privacy legislation.
Personal Information
Personal information is any information about an identifiable individual, including any information that, alone or in combination with other information, could be used to identify an individual. Personal Information includes, but is not limited to a Customer’s name, home address, email address, telephone number, date of birth and purchasing information, (in this Privacy Commitment referred to as “Personal Information”). Personal information does not include aggregated information, or any personal information that has been de-identified through the removal of potentially identifying details, such that the data may not be identified with a particular individual.
Purposes
Soghaat generally collects, uses and discloses Personal Information to operate our businesses and to administer our Programs, including for the following purposes (the “Purposes”):
To communicate with Customers regarding orders, purchases or any concerns or queries the Customer may have;
To communicate with Customers regarding any changes to this Privacy Commitment or to Programs and their operation;
With consent, or as permitted by law, to communicate with Customers regarding promotions, contests, offers, incentives, rewards, surveys, questionnaires and other pertinent matters such as but not limited to products and services under the Programs or available through Partners that may be of interest to the Customers;
To ensure Customers are appropriately awarded points or their equivalent in accordance with the rules of the applicable Program and receive reward redemptions in accordance with applicable Program Rules and that rewards records are appropriately maintained;
To process information regarding Customer orders, purchases and the collection and redemption of points and rewards;
To provide services, rewards, products and benefits to Customers and to enable them to participate in contests;
To understand and analyze the interests, needs and preferences of Customers;
To develop, enhance, market, recommend and/or provide products and services to meet the needs and interests of Customers and potential customers;
For marketing and analytics purposes, including to display targeted advertising as set out in the Interest-Based Advertising section below;
To verify Customers’ identity, when required or desirable for transaction purposes, so as to reduce fraud or errors in tranSaction processing;
To comply with applicable legislation and regulatory requirements; and
For investigation and law enforcement purposes.
Soghaat does not collect Personal Information from Customers other than for the purposes identified in this Privacy Commitment, unless further consent is obtained, or where otherwise required or permitted by law.
Soghaat collects Personal Information from Customers in several ways, including but not limited to, at the time of enrolment in a Program, when subscribing for email communications, when visiting one of our stores, when a purchase, return, inquiry or Program redemption is made by a Customer both in-store and online, through Partners, through online use of any of our websites or Program website, through use of one of our mobile apps, through Customer interaction with customer services offered by Soghaat and/or Program(s), through surveys or questionnaires or other research conducted by or on behalf of Soghaat or a Partner and through contests entered by a Customer.
We also collect Personal Information from
(a) individuals when they apply for employment through a Soghaat website, in person at a store, or otherwise. We use this Personal Information solely for the purpose of processing and responding to such applications; and From time to time, we may share your Personal Information with third party service providers that we have engaged to perform services on our behalf, based on our instructions, such as advertising agencies, marketing agents, data processing and storage companies or organizations which provide administrative and support services to Soghaat. We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal
Information solely to provide Soghaat with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us at the addresses provided under “Contact Us”.
(b) prospective and current franchisees and affiliated merchants, and their principals. We use this Personal Information for the purpose of processing and responding to franchise and affiliated merchant applications and in ongoing dealings with such parties, and as may be otherwise set out in communications and agreements with such persons.
In this Privacy Commitment, references to “Customers” also apply to the individuals referred to in paragraphs (a) and (b) above with any changes necessary in the circumstances.
Sharing
From time to time we may disclose to third parties aggregated or de-identified data, which does not contain Personal Information or other information regarding identifiable individuals. Soghaat may share or transfer your Personal Information where reasonably required in the context of a sale, merger, reorganization or amalgamation of all or part of our business or the insurance of securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is completed, assignees or successors of our business or assets may use and disclose your Personal Information, as obtained from Soghaat only for the purposes set out this Privacy Commitment, unless your further consent is obtained.
Soghaat may also share your Personal Information with third parties as required or permitted by law, such as: to government bodies and law enforcement agencies, pursuant to warrant, order or statutory requirement; in connection with any legal proceedings or prospective legal proceedings involving Soghaat; to otherwise establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and reducing credit risk), as permitted by law Soghaat does not otherwise share, give, rent or sell your Personal Information to any third parties, unless your additional consent to do so is obtained.
Soghaat will take reasonable measures to ensure that the Personal Information we collect is accurate and complete. We will update our records regarding Customers based on the information communicated directly or indirectly to us by Customers or Partners. In order to ensure that our records are as complete and accurate as possible, you are responsible for informing Soghaat of any relevant changes to your Personal Information, such as a change of name or a change of address or other contact details.
Our websites may contain links to other websites. We are not responsible for the privacy practices or the content of sites (other than our own sites) to which we provide links. You should check the privacy policies of these other websites before choosing to provide any Personal Information to such third-party sites.
Cookies and Tracking Technologies
When you visit one of our websites or use one of our apps, we may use certain automated tools to provide you with a more personalized browsing experience, better understand your needs, provide you with content that is most relevant to you and monitor trends respecting the usage of our site and apps.
In general, you can visit one of our websites without telling us who you are or submitting any personal information. However, through log files and other technologies, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as page requests, browser type, operating system and average time spent on our websites. We collect similar information respecting the usage of our apps. We use this information to help us understand user activity on our websites, to provide you with content appropriate for your region, and to monitor and improve our websites.
Cookies: Our websites use a technology called “cookies”. A cookie is a small text file stored on your device that identifies your browser/device/IP address – but not you as an individual – to our computers each time you visit one of our websites. More information about cookies can be found at www.en.wikipedia.org/wiki/HTTP_cookie.
We use cookies on the pages on our websites where you are prompted to log in or that are customizable. If you have registered with our websites, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to provide personalized services, and (3) will provide us and our service providers with information that we will use to personalize our websites in accordance with your preferences and interests. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies (these controls are typically found in the privacy settings for your browser). You do not need to
enable cookies to visit our websites; however, if you decide not to accept cookies when visiting one of our websites, you may not be able to take advantage of all of the features of that site. Tracer Tags & Web Beacons: Our websites may also use a technology called “tracer tags” or “Web Beacons”. A web beacon [https://en.wikipedia.org/wiki/Web_beacon] is a small transparent graphic image that allows us to record simple user actions related to our websites and to email communications received from us, to help us determine the usage and effectiveness of our site and communications. These “images” are automatically loaded to your browser/device when you visit the website or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. This technology allows us to understand which pages you visit on our websites. These tracer tags are used to help us optimize and tailor our websites for
you and future visitors.
Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the websites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the convenience of the websites. For more information or to opt-out, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
Interest-Based Advertising
General
We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our websites and apps and other websites and apps in order to provide you with tailored advertisements on our behalf on third party websites across the Internet. These companies may collect information about your activity across your different devices on our websites and apps and third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver
ads that are more relevant to you on third party websites and apps. This information may also be used to evaluate our online advertising campaigns. To opt-out of receiving online behavioral advertising from third party advertising companies who collect data on our websites, please click on the AdChoices icon located in the top right hand corner of any of our websites.
For more information about interest-based advertising on your desktop or mobile browser and to understand your options, including how you can opt-out of receiving behavioral ads from third-party advertising companies participating in the DAAC, please visit the Digital Advertising Alliance https://digitaladvertisingalliance.org.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes, including to produce aggregated website analytics, and you may still see ads from us; however, the ads will not be targeted based on behavioral information about you, and may therefore be less relevant to you and your interests. To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to a particular web browser you have used, so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt-out again.
Social Media Advertising
We may also use services provided by third-party platforms (such as social networking platforms, search engines and other third-party websites) to serve demographically-targeted advertisements on such platforms to users of those platforms, based on user data collected by the operators of those platforms. Generally, your receipt of advertising on such platforms is governed by the privacy policy, terms of use, and preference options provided by the provider of the platform in question. From time to time, we may also engage third-party platforms to serve users of those platforms with more individually-targeted advertising, which is based both on the platform’s user data and your
interactions with Soghaat outside of the platform. To do this, we provide to the platform provider a “hashed version” of your email address or other potentially connecting information, which could be matched to your profile with that platform. Hashing is a mathematical operation that applies an equation to information so as to produce an encrypted value that cannot be reversed to reveal the original data. Both Soghaat and the platform run the same one-way hash function on the same data element, for example, an email address. As a result, when Soghaat provides the platform with the hashed email addresses of a selected group of Customers, the platform is able to match the hashed value against the corresponding hashed value for users of the platform, allowing the platform to target Soghaat customers that are users of that platform with relevant advertising, based on demographic and other factors selected by Soghaat. Soghaat provides only the hashed value and no other information about you to the platform. Further information about this process may be provided by the social media platforms that you use (see, for example, the “ads” icon in Facebook’s user Privacy Settings and Tools), and you may exercise the preferences provided by those social media platforms with respect to your viewing of advertising on those platforms. To opt-out of the use by Soghaat of the Personal Information we hold about you for such purposes, please see Your Options.
Retention
Soghaat will only retain Personal Information to the extent necessary for the purposes identified in this Privacy Commitment, or to which you might otherwise consent, after which your Personal Information will be securely destroyed or irreversibly erased or de-identified. Personal Information may be stored “in the cloud” or otherwise outside of Canada, where it may be subject to the legal regime of the jurisdiction in which it is stored.
As noted below, under Your Choices, you may cancel your membership in a Program or otherwise request deletion of your Personal Information. Note that, in some cases, Soghaat may retain some of your Personal Information for a reasonable period of time for legal, administrative or compliance purposes.
Security
Soghaat has established appropriate technological, physical and contractual security measures designed to help protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information.
Your Options
Soghaat provides you with a number of options through which you may exercise certain preferences with respect to our use of your Personal Information, obtain access to the Personal Information that we hold about you, or request revisions to or deletion of that information.
Opting Out
You may generally withdraw your consent to our use or disclosure of your Personal Information at any time, subject to legal and contractual restrictions; however, without such consent, we may be unable to provide you with certain services or benefits. For example, if you withdraw your consent for the use of your Personal Information for the purposes of earning points or other benefits under a Program, we will no longer be able to participate in that Program.
Direct Marketing
From time to time, with your consent or as otherwise permitted by law, we may use Personal Information to communicate with Customers regarding promotions, contests, offers, incentives, rewards, surveys, questionnaires and other pertinent matters such as products and services, as described under Purposes , above. If you would prefer not to receive such communications from us, you may opt-out at any time by contacting Soghaat at the addresses provided under “Contact Us”. If you receive promotional email messages from us, you may also unsubscribe from such messages by using the unsubscribe mechanism found in all such messages. Opting out from the receipt of direct marketing material will not affect your privileges or ability to participate in a Program, nor will it prevent the provision of periodic statements to you with respect to any point or similar balances in a Program.
Interest-Based Advertising
As described above, under Interest-Based Advertising, you may opt-out of receiving online behavioral advertising from third party advertising companies who collect data on our websites by clicking on the AdChoices icon located in the top right hand corner of any of our websites. You may also opt-out of Interest-Based Advertising more generally by clicking on the AdChoices icon on any ads that you see.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads on many of the Internet sites that you visit; however, these ads will not be targeted based on your perceived interests and tastes, and may therefore be less relevant to you. As also described above, you may opt-out of having Soghaat using the Personal Information it holds about you to target ads to you when you are on social media platforms.
Access and Correction
Upon request, Customers may examine the Personal Information about them that Soghaat holds, except as provided by law. Where Soghaat is unable to provide access to all the Personal Information it holds about you, it will provide the reasons why it is unable to do so. Where Soghaat receives a request from a Customer to examine Personal Information collected and retained, Soghaat will respond to the request within 30 business days.
You may request access to your Personal Information by making a request, in writing, to Soghaat Privacy Officer, at the addresses provided under Contact Us. Note that, in an effort to prevent fraudulent or unauthorized requests for access, we may request identification for authentication purposes.
You may also make a subsequent request to the Soghaat Privacy Officer to correct any Personal Information that you feel is inaccurate or incomplete. You may also request the deletion of your Personal Information, subject to legal and contractual restrictions; however, please note that deletion of some information may impact our ability to provide you with certain services.
Changes and Updates
Soghaat may revise this Privacy Commitment from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services.
When we make changes to this Privacy Commitment we will revise the “last updated” date at the top of the Commitment. You should check back here periodically to find out if any changes have been made. If we make substantial changes we will, as appropriate, prominently post these changes to our website or notify registered Customers directly.
If you disagree with any change to the Privacy Commitment, you may close your account and refrain from using our services, or in some cases, by opting out. Continuing to use our services, including our websites, after we post or communicate a change signifies that you consent to the revised terms of the Privacy Commitment.
On occasion, we may also identify new purposes for the collection or use of Personal Information, such as in connection with a new promotion or Program. We will describe such uses in separate notices or other communications.
Should you have any questions about this Privacy Commitment, or the manner in which Soghaat collects, uses, shares and protects your Personal Information, you may write to our Privacy Officer at the postal or email addresses provided below.
Contact Us
Canada

Mississauga

6400 Millcreek Dr. Unit 5, Mississauga

Telephone: +1(905) 821-3727

E: support@soghaat.com