King West Group Inc., a company registered in Ontario, Canada, hereinafter referred to as ‘King West Group’ or ‘We’ have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that You provide to us when using righthill.com (the ‘Site’) and the King West Group Services. In this Statement, references to ‘You’ and ‘Your’ are references to the Right Hill Member. When You use the Site and the Right Hill Services, You are consenting to the practices set forth in this Statement.
We know that Your privacy is very important to You which makes it very important to us. We aim to be as clear as possible in this Statement in respect of Your Personal Data. This Statement applies inter alia to Your Personal Data that We collect about You when You use the Site, how and when it is used, how We protect it and who has access to it.
YOUR ACCEPTANCE OF THE STATEMENT
This Statement governs Your use of the Right Hill Services, including any dispute concerning privacy. By using the Right Hill Services, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the Site and the Right Hill Services. We reserve the right to modify this Statement at any time without notice by posting the changes on this page. Your continued use of any portion of the Site following the posting of the updated Statement will constitute Your acceptance of the changes.
WHAT INFORMATION IS COLLECTED & HOW?
The Site asks You to provide various types of Personal Data to enhance the quality of the Right Hill Services We can provide to You and the more accurate the information You provide, the better We are able to respond to Your requirements! As part of the process of using the Site and the Right Hill Services, We may collect the following types of Personal Data about You (as applicable):
- Your first name, last name, email and password (upon Sign-Up as a Right Hill Member on the Site);
- Your gender, house number, date of birth, postcode and photo (upon further entering a Prize Draw and accruing Entries in Your Entries Bank by undertaking certain Right Hill Member Actions);
- Your visits to the Site and the Right Hill Content that You download.
- information about Your computer (including Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Site navigation);
- any other information that You choose to send to us, including any request for further Right Hill Services, general correspondence, reports of a problem with the Site or the Right Hill Services.
- information relating to any Prize Draws entered in to by You on the Site and any Prize Draws which You have been a Winner.
Other de-personalized data which does not record Personal Data as such, rather information such as the date of Your visit to the Site, the path taken, the browser used, the IP address etc. is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning for Right Hill Members and to draw conclusions upon demographic information.
HOW IS THE INFORMATION USED?
You hereby expressly consent to Your Personal Data being passed on to third party companies or service providers for the sole purpose of fulfilling the Right Hill Services only (including making improvements to the Right Hill Services) and not for the purposes of those third parties making marketing communications to You, unless You have expressly consented to this being undertaken by a third party (“Right Hill Partners”). Right Hill Partners include our Right Hill Retailers who provide the Prizes so although You are under no obligation to provide such Personal Data to us, however, if You choose not to, some of the Right Hill Services may not be available to You.
You acknowledge that Your Personal Data may be used by Right Hill to contact a Right Hill Member by post, phone or by electronic mail when necessary in connection with Your use of the Site and the Right Hill Services including Your Right Hill Membership.
From time to time, Right Hill may contact You by electronic mail (or by telephone) by way of sending You various confirmations, notifications, feedback requests or any other newsletter or information or offers regarding upcoming Right Hill promotions, services or customer surveys. If You change Your mind, You can opt out of receiving some but not all of this as some are required as a necessary part of delivering the Right Hill Program and for operating the Right Hill Membership in order to continue to receive access to the Right Hill Services. You cannot opt out of receiving the Right Hill Membership Verification Email, the Right Hill Membership Email or the Winner Alert.
You can opt out of receiving direct marketing communications from Right Hill as described below.
Your Personal Data is used solely by Right Hill (and Right Hill Partners to the extent necessary to fulfill the Right Hill obligations to You and the Right Hill Retailer obligations to You where applicable) for the sole purpose of enabling Right Hill to act as a service provider to You and is not shared with any person or company without Your express consent.
Any Personal Data that is held with Right Hill shall be retained in accordance with the Data Protection Act 1998 and related Data Protection Legislation and/ or our retention and destruction policy culminating in its permanent deletion.
If Personal Data has been passed to third parties with Your consent, You may need to contact them separately if You change Your mind in relation to their use of Your Personal Data.
OPTING OUT: If You do not wish to be contacted by Right Hill in respect of future marketing communications, We will give You the opportunity to unsubscribe to the receipt of such communications in every electronic mail communication that We send to You. Alternatively and additionally, You can contact Right Hill by sending an email to this email address with “UNSUBSCRIBE REQUEST” in the subject line or send Your request by post to Right Hill at the contact address below.
WHO HAS ACCESS TO YOUR PERSONAL DATA?
To minimize the risk of unauthorized access to Your Personal Data, We use some of Your Personal Data to authenticate You when using the Site and the Right Hill Services.
For our daily operations, We may use the Right Hill Services of third parties to provide some of our business and operational functions. Consequently, some of the Right Hill Services are provided by Right Hill Partners and We need to disclose Your information to them to provide You with the Right Hill Services.
Disclosure of Your Personal Data in Compliance with Laws
You should be aware that We may release Your Personal Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transact or communicate with or via Right Hill, or to protect the rights, property or safety of Right Hill, Right Hill Members or third parties.
Transfer of Your Personal Data outside of the EEA
From time to time, We may transfer Your Personal Data to a related company, agent or contractor in order to improve our Right Hill Services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and You consent to the transfer of Your Personal Data to such companies for the purposes set out here in accordance with this Statement and as permitted by the Data Protection Legislation from time to time.
Transfer of Personal Data in the Event of the Sale of righthill.com or its Assets
In the event that righthill.com is sold or transfers some of its assets to another party, Your Personal Data could be one of the transferred assets. If Your Personal Data is transferred, its use will remain subject to this Statement. Your Personal Data will be passed on to a successor in interest in the event of a liquidation or administration of Right Hill.
HOW DO WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG?
The privacy and protection of Your Personal Data is important to us. In addition, any Right Hill Member statistics that We may provide to prospective Right Hill Partners regarding Your usage of the Right Hill Services are provided in the aggregate only and do not include any individually identifiable data.
You acknowledge that email messages sent over the Internet are not encrypted and are not secure. Despite efforts to protect Your Personal Data, We cannot ensure or warrant the security of any Personal Data You transmit to us, via, to, or from our Site. You accept that Right Hill cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential Personal Data, which You do not wish to communicate by email, please contact Right Hill by telephone or post to arrange an alternative method of communication. You transmit all such Personal Data at Your own risk.
How long We keep Your Personal Data collected through our Site depends on the context in which You provide it and the purpose for which We use it. We will only retain it for as long as is necessary for such purposes. We may send You direct marketing communications for as long as You do not unsubscribe from receiving the same from Right Hill.
Telephone calls: If You call any of the service telephone numbers quoted on this Site, We may record Your call. These recordings are used for training and quality control to ensure that We continuously monitor and improve our service standards.
COMPLAINTS OR QUERIES
Right Hill tries to meet the highest standards when collecting and using Personal Data. For this reason, We take any complaints We receive about this very seriously. We encourage You to bring it to our attention if You think that our collection or use of Personal Data is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
HOW TO CONTACT US
Requests for information about our Statement or a ‘subject access request’ can be emailed to [email protected]
King West Group Inc. owner of righthill.com
CHANGES TO THIS STATEMENT
We keep our Statement under regular review. This Statement was last updated on November 17, 2020.