2775882 Ontario Inc., o/a “PUTNAM HOLDINGS NETWORK” takes the protection of your personal information seriously. This Privacy Policy describes how we collect, use, disclose, transfer, retain, and otherwise process your personal information (as defined below) in any format during your visit to this website (phnetwork.ca) or other websites or platforms controlled by 2775882 Ontario Inc. that direct visitors to this Privacy Policy (“Website”), as well as when you purchase our products and services, or otherwise communicate or interact with 2775882 Ontario Inc. in person, by phone, by mail or electronically.
By visiting our Website, purchasing our products or services, or by otherwise interacting with us online or offline, you are agreeing to the terms of this Privacy Policy.
This Privacy Policy applies to and governs the activities of 2775882 Ontario Inc., its Canadian subsidiaries, affiliates and partnerships in which 2775882 Ontario Inc. and/or its Canadian subsidiaries and affiliates have a majority interest (collectively referred to herein as “the PUTNAM HOLDINGS NETWORK”, “we”, “us”, or “our”). The PUTNAM HOLDINGS NETWORK of companies refers to 2775882 Ontario Inc. and any affiliates/related companies throughout the world.
Importance notice to non-Canadian residents
Please be aware that our Website and our products and services are directed to individuals in Canada. If you are located outside of Canada and choose to visit our Website or other PUTNAM HOLDINGS NETWORK websites and platforms, or purchase our products or services, or otherwise communicate or interact with PUTNAM HOLDINGS NETWORK in person, by mail, by phone or electronically, please be aware that your information may be transferred to, processed, maintained, and used on paper, computers, servers, and systems located outside of your province, territory, state, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin, and you do so at your own risk.
Who we are
PUTNAM HOLDINGS NETWORK is a holdings company of number websites and businesses in various industries. We sell products and services to customers in various sectors and countries in the world.
Personal information we collect
We may collect, use, process, disclose and retain personal data in the course of you visiting our Website, purchasing our products or services, or otherwise interacting with us online or offline, including but not limited to the following personal information:
- Contact information such as your name, email and postal address, and telephone number;
- Biographical information such as your date of birth;
- Billing and financial information such as billing address, bank account number, credit card number, and payment history;
- Marketing and communication preferences and related information such as feedback and survey responses;
- Business information such as PUTNAM HOLDINGS NETWORK product and services purchases and use of products and services; and
- Technical information such as your internet protocol (IP) address, name of your internet service provider, information about your internet browser, website you were on immediately prior to landing on a PUTNAM HOLDINGS NETWORK website, and date/time of your visit to our websites.
How we use your personal information
We use your personal information for the following purposes:
- To develop, implement, market, promote and sell products, services, and special offers;
- To purchase, acquire and solicit products, services, and special offers from our suppliers;
- To manage our business and provide day-to-day services including, but not limited to, ordering, shipping, delivering, invoicing, collecting, establishing credit arrangements, administering rebates, discounts and special programs, processing payments, managing accounts, and supply chain activities;
- To investigate and respond to customer inquiries and complaints;
- To establish customer, supplier, distributor, and retailer relationships and to communicate with customers, suppliers, distributors, and retailers;
- To research, develop and improve existing and new products, technologies, and services;
- To provide information and training to customers, suppliers, distributors, and retailers about existing and new products and services of PUTNAM HOLDINGS NETWORK, including the use of such products and services;
- To manage and promote the business activities of PUTNAM HOLDINGS NETWORK, including the development and evaluation of business plans;
- To review and assess market trends and activities impacting the business of PUTNAM HOLDINGS NETWORK;
- To secure and protect the safety and well-being of our customers, suppliers, distributors, retailers, the community and the environment;
- To better understand our customers, online visitors, suppliers and service providers, we may analyze your information in aggregate form (which will not identify you personally);
- To administer or enforce our rights under an agreement or otherwise protect PUTNAM HOLDINGS NETWORK and its rights;
- To develop and manage our business and operations;
- To carry out other purposes which are identified to you and to which you consent; for example, in any terms of use or agreements related to a specific product or service of PUTNAM HOLDINGS NETWORK;
- To meet requirements imposed by law; including court orders, subpoenas, or compliance with the legal process; and
- To facilitate reorganizations of our business, including change of ownership, sale, merger, liquidation, acquisition and transfers.
With whom we share your personal information
Your personal information may be shared and processed by other parties including:
- Any entity or person with your consent;
- Any entity or person within the PUTNAM HOLDINGS NETWORK (in aggregate and non-aggregate forms) for the purposes described in this Privacy Policy;
- Third parties who provide services to us or on our behalf for the purposes described in this Privacy Policy, including but not limited to, ecommerce, IT, application development, maintenance, marketing, database management, data processing, risk management, office support, logistics services, payment processing, and customer service, but only to the extent needed to enable them to provide such services;
- Law enforcement, government, and regulatory agencies, courts of law, other public and government authorities, and other third parties in accordance with legal requirements;
- Third parties to administer or enforce our rights under any agreement;
- Any person or entity in emergency situations that threaten the life, health or security of an individual, the community or the environment;
- Agents, current and prospective business partners, and other third parties in aggregate form; and
- Third parties in the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of 2775882 Ontario Inc. or a 2775882 Ontario Inc. business unit or department or product(s).
Third parties may not use or disclose personal information for any purpose other than providing the services on our behalf or our affiliates’ behalf or for any purpose other than as set out in this Privacy Policy or as otherwise required by applicable law.
Where personal information will be stored
As PUTNAM HOLDINGS NETWORK is accessible globally, we use the resources of our affiliates and third-party service providers to process and store personal information for the purposes described in this Privacy Policy. This may involve your personal information being stored or processed within Canada (but outside the province/territory in which you reside) or any other country where the service providers, PUTNAM HOLDINGS NETWORK or its affiliates maintain facilities. In the event we transfer your personal information to another province/territory within Canada or outside Canada:
- When we engage third parties to provide services to us, we will endeavour to use contractual means to help ensure a comparable level of protection is maintained while the personal information is in the possession of the third party. In some cases, these third parties may be located in Canada but outside of the province/territory in which you reside, or outside of Canada (e.g. the United States, Germany and/or India) and the personal information may be subject to the laws of that jurisdiction and no contractual provision can override those laws. Similar to Canadian law, where third-parties are located outside Canada, law enforcement agencies or other governmental authorities in the United States or other jurisdictions may obtain access to personal information where access is permitted or required by the law of the applicable jurisdiction. Confidentiality and the security of information are key considerations for PUTNAM HOLDINGS NETWORK in any outsourcing arrangement to third parties, both inside and outside Canada. To access information about our policies and practices with respect to service providers outside Canada, please contact our Privacy Officer, who is able questions about such service providers.
- When we disclose your personal information to PUTNAM HOLDINGS NETWORK and its affiliates, the personal information may be subject to the laws of that country. We require our affiliates to take appropriate steps to safeguard personal information in line with locally applicable data protection requirements.
How long we keep personal information
We keep your personal information as long as necessary to fulfil the identified purposes, or as required or permitted by law.
How we protect your personal information
We take the security and privacy of your personal information very seriously. Accordingly, we implement reasonable physical, organizational, and technological security measures designed to protect the confidentiality of your personal information against loss, theft and unauthorized access, misuse, disclosure, copying, use, and modification, taking into account the risks involved in processing and the nature of such personal information. Reasonable measures may include locked filing cabinets and restricted access to offices or designated areas; using security clearances, passwords, firewalls, and encryption; and limiting access on a “need-to-know” basis, each alone or in combination depending on the nature of such personal information. Please understand, however, that no security system is completely secure. We cannot guarantee the security of any personal information that you transmit, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email. Any transmission of your information is at your own risk.
Your rights
Consent
We collect, use, and disclose your personal information with your consent as permitted or required by law. Your consent to our collection, use and/or disclosure may be express or implied.
Usually, we will seek your consent to use and/or disclose your personal information at the time of collection. In some circumstances, we may seek consent after we have collected your personal information but before we use it (for example, if we want to use the personal information for different purposes than previously identified).
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Please send all communications with respect to the withdrawal of your consent or any change to your consent in writing, addressed to our Privacy Officer.
In most circumstances, we will collect your personal information directly from you. From time to time and with your consent where required by applicable law, we may engage others, such as our distributors or retailers of our products, to collect your personal information on our behalf.
Accuracy
We will try to ensure that your personal information is accurate, complete and up-to-date as necessary for the purposes for which it will be used.
Individual Access
We will provide access to your personal information upon your written request to our Privacy Officer using the contact information below, to the extent required by law. We will attempt to respond to your written request within thirty (30) days. We will advise you in writing if we cannot meet your requests within this time limit. You may challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.
Accountability, Openness, and Compliance
We are responsible for all personal information under our control.
We have designated a Privacy Officer who is accountable and responsible for compliance with this Privacy Policy and addressing inquiries and concerns. If you have questions or concerns about this Privacy Policy and our procedures, please contact our Privacy Officer as set forth below.
Cookies
We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer or device will “remember” information about your visit. We use both first and third-party session cookies and persistent cookies. Where available, the ability to accept cookie placement may be found in a cookie banner first displayed on the Website and, if available, in the cookie preferences.
Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose and the cookie preferences, if available, may have additional information. For more information, please see Information from Third-Party Analytics Providers below.
- Session Cookies: We use session cookies to make it easier for you to navigate our Website and other PUTNAM HOLDINGS NETWORK websites and platforms. A session ID cookie expires when you close your browser.
- Persistent Cookies: A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on our Website or other PUTNAM HOLDINGS NETWORK websites or platforms, persistent cookies can be used to store your passwords so that you do not have to enter it more than once. Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on our Website or other PUTNAM HOLDINGS NETWORK websites or platforms.
In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Website or other PUTNAM HOLDINGS NETWORK websites or platforms (e.g., email open rates, URL click-throughs).
If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device and, where available, may decline the placement using a cookie banner. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies via your browser. However, if you decide not to accept cookies from us, certain aspects of our Website or other PUTNAM HOLDINGS NETWORK websites or platforms may not function properly or as intended.
Site Analytics, Ad Networks, Cookies, and Web Beacons
We may use one or more third–party analytics services to evaluate your use of our Website or other PUTNAM HOLDINGS NETWORK websites or platforms, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, recordings of site and/or screen interactions, and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.
By accessing and using our Website or other PUTNAM HOLDINGS NETWORK websites or platforms, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website or other PUTNAM HOLDINGS NETWORK websites or platforms.
For Google Analytics, please visit: https://marketingplatform.google.com/about/analytics/
We may also use third-party ad networks, which may use cookies and web beacons to collect non-personal information about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. Please note that we do not have access to or control over the cookies that are used by these third-party ad networks.
DIRECT MARKETING
If you give us consent to send you topic-related information, including information on PUTNAM HOLDINGS NETWORK products, services, events and web seminars, we collect and process your personal information (including first name, last name, company (if applicable), email address, area of interest and birthday (for promotions, discount specials and greeting card mailers) in order to provide you with personalized topic information. In order to determine your needs and interests, we combine and analyze the personal information that we have collected about you in the course of your relationship with PUTNAM HOLDINGS NETWORK as a customer or user of PUTNAM HOLDINGS NETWORK products and services (in particular your contract and master data, the products you have purchased, information that you have requested or downloaded, webinars for which you have registered, surveys that you have completed, newsletters you have signed up for, comments that you have made, etc.).
Your consent to receive topic-related information, if given, also applies to the transmission of your personal information – depending on your location – to the PUTNAM HOLDINGS NETWORK affiliated companies to carry out related transactions. In addition, you consent to PUTNAM HOLDINGS NETWORK sharing your personal information between those PUTNAM HOLDINGS NETWORK companies which are responsible for the country in which you are situated as well as PUTNAM HOLDINGS NETWORK contractors when needed to achieve the goals herein. Both of the aforementioned transfers serve the purpose as described above.
We will share your personal information with other affiliated companies of the PUTNAM HOLDINGS NETWORK if they provide services for us or if this is necessary for operational reasons, such as print-on-demand orders, etc. Furthermore, we will pass on your personal information to the service providers we use from whom we obtain services to assist in delivery of your purchase. Our service providers are carefully selected and regularly checked by us. They process personal information only on our behalf and strictly in accordance with our instructions on the basis of corresponding contracts for order processing.
We store your personal information collected within the scope of your consent for the above-mentioned purposes until your consent is revoked.
The legal basis for the processing of your personal data for the above-mentioned purposes is your consent.
You can revoke your consent at any time with effect for the future by opting out in your account area. Each topic-related communication we will send to you based on this consent, will contain a separate link to revoke your consent. You may use the link within the email and follow the instructions found on the page to which the link takes you in order to opt out at any time from the use of your personal information for direct marketing purposes and/or the transfer of your personal information to third parties for direct marketing purposes. You may also opt out at any time from such use by contacting our Privacy Officer using the contact information below, provided, however, that you may be required to provide sufficient information that allows us to reasonably verify you are the person, or are an authorized representative of such person, about whom we collected such personal information. Please allow us a reasonable time to process your request.
You are at liberty to grant or withhold consent. This has no effect on your visit of this website and platform.
If you revoke your consent, we will no longer use your personal information for the specific topic-related purposes from which you have withdrawn, unless we have another legal basis for this. The revocation of your consent does not affect the legality of the data processing that has taken place up to that point. You cannot opt out of receiving transactional emails related to our products and services.
Children
We do not knowingly collect personal information from children under the age of 18 through our Websites. If you are under 18, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact our Privacy Officer as set out below for the purpose of deleting their personal information from our databases.
DO NOT TRACK AND GLOBAL PRIVACY CONTROLS
PUTNAM HOLDINGS NETWORK honours “Do Not Track” settings and “Global Privacy Controls”. You can go to this website to learn more about the Global Privacy Control signal and how to implement it: https://globalprivacycontrol.org/. If you are using an opt-out preference signal on your browser using these settings, the opt-out preference signal will apply only to that browser. The choices you make in response to any cookie banner will override the preferences you have made using the settings of your opt-out preference signal. Setting your opt-out preference signal within your browser will enable PUTNAM HOLDINGS NETWORK to honour that signal in a frictionless manner.
Links to external websites
The Website may contain links to third-party websites. These third-party websites may collect information about you if you click on a link and may automatically record information about your browsing behaviour every time you visit a site. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.
The Website may contain features that allow you to chat via text with an automated response system or a live person. We and the third-party provider of the chat feature may retain a transcript of any such chat conversation. The third-party provider may use the transcript related to its provision of services and products. The third-party provider may collect personal information about and during your use of the chat feature, and such information would be subject to their privacy policies.
Affiliate Links
We may include affiliate links on our Website. If you click on an affiliate link and make a purchase through that link, we may receive a commission from the retailer. Please note that we only recommend products or services that we genuinely believe will be of interest and value to our readers. Your use of affiliate links does not affect your privacy rights or obligations under this Privacy Statement.
Amendments to this policy
This Privacy Policy is effective as of the “last updated” date at the bottom of this Policy. We reserve the right to modify this Privacy Policy at any time and for any reason with or without notice to you. By visiting the Website, purchasing our products and services, or by otherwise interacting with PUTNAM HOLDINGS NETWORK in person, by phone, by mail or electronically after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your personal information is governed by the Privacy Policy in current effect. We encourage you to refer to it on a regular basis.
Contact us
We have designated a Privacy Officer who is accountable and responsible for compliance with this Privacy Policy and addressing inquiries and concerns. If you have questions or concerns about this Privacy Policy and our procedures, please contact our Privacy Officer at:
Contact Form
Email:
privacy@phnetwork.ca
Mail:
PUTNAM HOLDINGS NETWORK
402 – 1770 Paris Street
Sudbury, ON P3E 3C3
Attn: Mirkka Putnam (re: phnetwork.ca)
Please include the related website and as much detail as possible when contacting the Privacy Officer to provide the best outcome for your concerns or solutions to your question(s).
Office of the Privacy Commissioner of Canada
The Office of the Privacy Commissioner of Canada oversees our Personal Information handling practices. If any privacy concerns are not addressed to your satisfaction you may contact the Office of the Privacy Commissioner of Canada for further guidance:
By Phone: 1-800-282-1376 or 819-994-5444
By Fax: 819-994-6591
Website: http://www.priv.gc.ca
Last Updated: 2024-02-06