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Customer Privacy Policy

TELUS Agriculture & Consumer Goods Privacy and Data Use Policy

Last Updated: September 27, 2022

Your Privacy is Important to Us

This Privacy Policy (“Policy”) applies to the Processing of your personal information by GRAY S INC Inc. and its Affiliates d/b/a TELUS Agriculture & Consumer Goods (“TAC,” “we,” “us,” and “our”). At TAC, we believe that an important part of protecting privacy is to be clear about how we handle personal information, and to make information about our approach easily accessible. We have developed this Policy to outline how we protect the personal information entrusted to us by you. This Policy is current as of September 27, 2022. We may change it from time to time, and post the changes to our Site, so please be sure to check back periodically. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will try to provide you with notice in advance and highlight the change on our Site. When required under applicable laws, we will also seek your consent.

Scope of this Policy

This Policy applies to the Processing of your personal information by GRAY S INC Inc. and its Affiliates (“TAC,” “we,” “us,” and “our”). In particular, this Policy applies to personal information collected through:

Any TAC website on which we post this Policy (our “Sites”);
Our mobile or downloadable applications, web-based applications or SaaS platforms (our “Apps”); and
Any offline collection, either within or outside the use of our Sites and Apps

Our Sites, Apps, and any offline services are collectively referred to as “Services”.

Where we provideServices designed for business Customers, we act as a Processor, and the business Customer is the Controller of any personal information it provides or that we collect on its behalf. In these instances, the business Customer is responsible for providing any required privacy notices or rights to its End Users. End Users should contact the business Customer directly to exercise any rights available to them.

Sometimes, we may act as a Controller for personal information that we Process. In that case, the specific TAC entity with which you interact will be the Controller. A list of all the TAC entities which may be Controllers can be found here.

The application of this Policy is subject to the requirements or provisions of any applicable legislation, regulations, agreements or the ruling of any court or other lawful authority. Please also see the respective country/region-specific sections below for additional information about our Processing of personal information from those jurisdictions.

Acknowledgement

By using the Services, you acknowledge that we will handle your personal information as described in this Policy and any agreement you have entered into with us.

Consent

To the extent required by applicable law, TAC obtains any consents necessary for the Processing of personal information as described in this Policy. However, where TAC does not have a direct relationship with the End Users, we rely on our Customers to obtain all necessary consents or otherwise have all necessary authority we require for the Processing of End User personal information.

Information We Collect About You

We may collect personal information directly from you or automatically through your use of our Services. For example, collection may happen when you create an account, request information from us, access our Services, subscribe to communications, or attend our events. We may also collect information from third party sources (including offline), such as social media, farm and business customers, or business databases and records.

Information We Collect From You or Third Parties

Depending on your interaction with us, we collect the following information, which may constitute personal information, in your jurisdiction:

your name, email, address (including country), phone number and log-in credentials
your company or farm name, website or industry sector
billing, shipping and payment information
communication preferences
any other information you voluntarily provide to us or that is necessary for us to provide the Services to you, such as agronomic data, farm production data, or any information about your land including digital shapefiles of field boundaries or field GPS coordinates
field boundaries or geo-location information with respect to fields

Information We Collect Automatically

We automatically collect information about your use of our Sites and Apps through cookies, web beacons, scripts, and other technologies. We do not typically combine this information with other information we collect about you, including your personal information (see also “Cookies and Other Tracking Mechanisms”). We may also collect or infer information about your preferences for particular Services when your usage activities indicate what your preferences are.

The types of information we automatically collect from our Sites and/or Apps include:

Domain name
Your browser type, language and operating system
Online browsing or ‘clickstream’ or behavioral data of your usage on our sites (e.g., length of time you visited, pages viewed, links clicked)
The webpage that led you to our Sites
Device identifiers, such as advertising identifiers, name and model, IP address, operating system type, name, and version
If necessary to provide the Service, your mobile device’s location information

How and Why We Use Your Information

We use your information, including your personal information, for the following purposes:

Service Provisioning/Transactional Purposes:

To communicate with you throughout your relationship with TAC
To understand your needs and preferences
To provide products and services that are tailored to your requirements
To diagnose technical problems and to maintain and enhance safety and security
To meet contractual, legal and regulatory requirements

Marketing Communications:

In accordance with applicable laws (and with your consent where required), we may use your information to send you:

newsletters, product and event information
marketing communications about our Services or those of the TAC Group Entities
marketing communications about products and services of other non-affiliated third-party entities that we think may be of interest to you.

Advertising:

To help us determine relevant advertising content and media and to create Custom Audiences
To evaluate the success of our advertising campaigns (including targeted advertising and offline promotional campaigns)
See the Ad Networks section discussed below.

Site and Product Improvement/Development/Research:

To develop, improve, update or create Services
To study how our Services are used, both on an aggregated and individualized basis
To administer surveys and questionnaires

Our Use of Aggregated/De-identified Data:

We may transform personal information (and, unless prohibited by our customer agreements, any other information we collect) using techniques such as de-identification, anonymization or pseudonymization. We may use such transformed datasets for research, Service improvement, development of new Services, marketing, advertising, trend analysis or other similar purposes to further our business objectives. We also may share such datasets with other entities as set forth below.

Legal Purposes:

To preserve our legal rights or comply with other legal obligations we might have, such as in connection with litigation or enforcement actions by regulators or law enforcement
To protect our operations and the rights and safety of our Customers, including to protect against, identify or investigate fraud or other criminal activity
To respond to requests from public and governmental authorities, including any outside of customers’ countries of establishment
To meet any other legal and regulatory requirements, including compliance with applicable laws and regulations outside of customers’ countries of establishment.

With Whom We Share Your Information

We may share your information, including personal information, with:

Service Providers. We share the information we collect from you with service providers who perform functions on our behalf, such as hosting services, payment processors, marketing agencies and any other entities that need access to this information to facilitate Service delivery.
Affiliates. As a global organization, we share personal information about you globally with the TAC Group Entities to provide Services to you and to contact you about your request for Services. Where permitted by applicable law, the TAC Group Entities may share your information within the Group for purposes of other Group members to market their own products and services to you. The TAC Group Entities may also use your information for product analytics, design, development, improvement and delivery purposes.
Advertising Networks. We share data with entities that perform targeted advertising on our behalf. Please see Ad Networks section below.
Other Entities: With your permission, we may share your information with other entities including banks, food processors, insurance companies, suppliers, growers and any other TAC customers.
Subprocessor List: A list of entities with whom we share your personal information is available at https://www.telus.com/agcg/privacy-policy/sub-processors.

We also share information in the following circumstances:

Business Transfers. If (i) we are acquired by, merged with, financed or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company or to our or their advisors, including as part of the diligence process by a prospective company/investor.
In Response to Legal Process. As necessary for “Legal Purposes”

Aggregate and De-Identified Information. We may share information that has been de-identified or aggregated, (in a manner that such information is no longer considered personal information under applicable laws) or pseudonymized with service providers or other parties, for research, Service improvement, development of new Services, marketing, advertising, trend analysis or other similar purposes.

Location of Service Providers and Data Centers

Your personal ‎‎information may be Processed and stored in any country where we or our service providers have facilities. By using our Services, you understand that your personal information may be Processed and stored outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, governments, courts, law enforcement or regulatory agencies in these countries may be entitled to access your personal information. We will continue to protect your information in accordance with this Policy.

Retention

Our Use of Cookies and Other Tracking Mechanisms

We, our service providers and ad networks use cookies and other tracking mechanisms to track information about your use of our Sites or Apps, to personalize content and provide targeted advertisements through third party advertising networks when you visit other sites (see Ad Networks). We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).

Cookies. A cookie is a small text file, often containing a unique identifier, stored by your web browser when you visit a website. Websites use cookies to help provide certain functions, and to personalize your web experience by remembering things like your language preferences or items in your shopping cart.

We use cookies to understand how you interact with our Services and selected third-party websites primarily with the aim of improving your user experience.

The following is a summary of how we use cookies:

Essential. TAC uses cookies that are essential for navigating and enabling certain functioning of our Services. For example, these types of cookies assist TAC in authenticating you and your device or allow us to administer secure websites. If you choose to disable these cookies, specific features of our Services may not be available.

Performance. We use cookies to understand how you use our Services in order to improve their performance. Performance cookies generate aggregated, de-identified information which provide insights into trends and usage patterns that may be used for business analysis, website and service improvements, and for determining performance metrics. For example, these types of cookies help track the number of visitors to our websites.

Selections. We use cookies to remember your selections while visiting or using a Service. These types of cookies allow us to recognize your device so that you do not have to provide the same information repeatedly. For example, we may use cookies to remember your language preferences.

Personalization. We use cookies to personalize your experience while visiting our Services. These cookies may be used to deliver content to you that is customized to your interests based on an inference from your browsing patterns on our Services or from your customer relationship with us. For example, a relevant offer about a Service may be displayed to you based on the existing Services you currently have with us.

Advertising and third-party cookies. We use cookies to deliver tailored advertising to you. We may work with advertising agencies to place cookies to help deliver ads on third-party websites where we purchase advertising. These types of third-party cookies enable us to understand what ads you see and interact with, both on our Sites and on third-party websites. This helps us to measure the success of our advertising campaigns. For example, when you click on a TAC ad on a third-party website, cookies are used to track the effectiveness of the advertising campaign.

Other similar technologies. In addition to cookies, TAC also uses pixel tags which are small transparent images embedded in a web page or an email. We use pixel tags in connection with cookies to help operate our services, website and emails. For example, we may include pixel tags in email messages or newsletters in order to determine whether or not they are opened or acted on or we may use them in our Services to track the activities of users. .

Disabling Cookies. Most web browsers automatically accept cookies, but you can accept, refuse or delete them through your browser. If you disable cookies in any way, some functions in our Services may not be available to you.

Analytics. On some of our Services, and where permitted by local law, we use automated devices and applications, such as Adobe Analytics and Google Analytics, to evaluate usage of our Services and to help us improve the performance of our Services and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn about your Adobe Analytics privacy choices, please visit https://www.adobe.com/privacy/opt-out.html. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to limit their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

Ad Networks

We may use network advertisers to place advertisements on third party websites or other media (e.g., social networking platforms). We may provide these advertisers with information, including personal information, about you to assist us with our advertising efforts and will obtain your consent where required by applicable law to do so.

In certain markets, we may disclose information (such as your email address) to Facebook Custom Audiences–so that we can better target ads and content to you and others with similar interests on other websites or media (“Custom Audiences”). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences. You may control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below. (for more information on Facebook Custom Audience go here or to opt-out, go to the Facebook ad preferences page)

You may opt out of many ad networks if you do not wish to participate by visiting the following websites:

Digital Advertising Alliance ("DAA") Consumer Choice Page
Network Advertising Initiative ("NAI") Consumer Opt-Out Page
Users in Canada: Digital Advertising Alliance Canada (“DAAC”) AdChoices Page .
Users in the European Union: European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.
Users in Australia: Your Online Choices Page .

Opting out from any company listed on one of the online advertising industry websites above will opt you out from that company’s delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising online. Where permitted by applicable law, you may continue to receive advertisements, for example, based on the particular website that you are viewing.

Security of Your Personal Information

We employ security measures appropriate to the sensitivity of the information we collect in an effort to protect it from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

You should take steps to protect against unauthorized access to your password, phone, device, and computer by, among other things, signing off after using a shared device, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Your Choices Regarding Promotional Emails

In accordance with applicable law (including, where required, with your consent), the TAC Group Entities may send periodic promotional and direct marketing emails to you. You may opt-out of promotional and direct marketing emails by following the opt-out instructions contained in the email. We will process opt-out requests in accordance with applicable law. If you opt-out of receiving promotional and direct marketing emails, we may still send you emails about your account or any services you have requested or received from us.

Children

Your Privacy Rights

As a data subject, you may have certain rights when it comes to how we handle your personal information. Depending on where you live, you may have the right to exercise some of the rights we have identified below. We will honor your requests within the time periods specified under applicable laws and, if permissible under law, we may charge a reasonable fee to respond to you. Send us your request by visiting “Contact Us”.

Access and Correction. You may have the right to access the personal ‎‎information about you under our control, how that information is being used, the nature of the Processing activity, the source of your personal information, the identity of the Controller, and ‎‎a description of the individuals and organizations to whom that information has been disclosed.

In some situations, we may not be able to provide access to certain personal information. For example, when disclosure would reveal personal information about another individual, if the ‎‎personal information is protected by a legal privilege, or if we are prevented by law, we cannot provide access. When we cannot provide access, we will notify you.

While we will make a reasonable effort to ensure that personal information we are using or disclosing is ‎‎accurate and complete, we rely on you to ensure that it is.‎ You can ask us to update or change information about you if it is inaccurate or incomplete.

Withdraw consent. You can change your mind and withdraw consent you had previously provided for our Processing of your personal information at any time. If you withdraw your consent, we may not be able to offer our Services to you. You may also have the right to to receive information regarding the consequences of refusing or withdrawing consent.

De-registration of account. In certain jurisdictions, you can request the de-registration of your account.

Object to or Restrict Processing. You can ask us to stop or restrict Processing of your personal information in certain circumstances such as, for example, when the information is inaccurate or if we have no legal right to keep using it.

We can continue to use your personal information after you have requested that we restrict Processing, where we need it in support of legal claims or to protect the rights of another person.

Data Portability. You can have your personal information transferred directly to another Controller if technically feasible.

Automated Decision Making. You can object to decisions made on automated processing or profiling that could have a significant impact on you. You also have the right to ask for information or review the decisions being taken by automated means which have legal effects on you or otherwise significantly impact you.

Anonymize. You may have the right to anonymize, block or eliminate unnecessary or excessive personal information.

Complaints. You may complain to your local supervisory authority if you have concerns about how we are Processing your personal information.

Additional Information for Individuals in the European Union and United Kingdom

The personal information we collect about you in our capacity as a controller and not as a service provider is controlled by GRAY S INC Inc., which is headquartered at Floor 23 - 510 W Georgia St, Vancouver, British Columbia, V6B 0M3, Canada, and where applicable, any other entities referenced in the list of Controllers.

The Legal Bases for Processing Your Personal Information. The following are our bases for Processing your personal information as a Controller:

We have a legitimate interest (for example in order to make improvements to our Services and to provide you with information you request.
We need to Process personal information about you to perform a contract or take steps to enter into a contract with you (for example, to provide our Services or to facilitate your free trial of our Services).
We must comply with a relevant legal or regulatory obligation (for example, where we are required to disclose personal information to a court or tax authority).
You have given us your consent (for example, when you consent to sharing your personal information with another party for their own marketing).
It is necessary to protect your vital interests.

For more information, please see Appendix A or Contact Us.

Retention of Your Personal Information. We retain your personal information for as long as necessary to provide our services to you, to fulfill the purposes described in this Policy and/or our business purposes, or as required by law or regulation.

Your Legal Rights.

Subject to certain exemptions, and depending on the processing activity we are undertaking, when we act as a Controller, individuals in the European Union and United Kingdom have certain rights in relation to their personal information:

Access, Correct, and Delete Your Personal Information. You have the right to request access to the personal information that we hold about you and: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the Controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

You can also ask us to delete your information. We are not required to comply with your request to delete personal information if the Processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

Restrict the Processing of Your Personal Information. You can ask us to restrict the use of your personal information in certain circumstances, such as, for example, when the information is inaccurate or if we have no legal right to keep using it.

We can continue to use your personal information after you have requested that we restrict Processing, where we need it in support of legal claims or to protect the rights of another person.

Object to the Processing of Your Personal Information. You can object to any processing of your personal information that has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms.

Data Portability. To the extent that we process your information (i) with your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.

Right to Obtain a Copy of Personal Information Safeguards Used for Transfers Outside Your Jurisdiction. You can ask for a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Economic Area or the United Kingdom.

Withdraw Consent. You can change your mind and withdraw consent you had previously provided for our Processing of your personal information at any time. We will explain at the time we request consent how it can be withdrawn.

Complaints. You may complain to your local supervisory authority if you have concerns about how we are Processing your personal information. In the UK, this is the Information Commissioner’s Office.

We welcome the opportunity to resolve any issues before you contact the supervisory authority.

How to Exercise Your Rights. To exercise any of the rights in this Policy, please send us a request at privacy@telusagcg.com and tell us what information you would like to access, review, correct, or delete. Where appropriate, we may forward your request to the relevant Controller for response.

We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law.

In some situations, we may not be able to provide access to certain personal information. For example, when disclosure would reveal personal information about another individual, if the ‎‎personal information is protected by a legal privilege, or if we are prevented by law. When we cannot provide access, we will notify you.

Cross-border Transfer of Personal Information Outside the European Union or United Kingdom. We may process, store or transfer your personal information outside of the European Economic Area (EEA) and the United Kingdom including in countries and jurisdictions that are not subject to an adequacy decision by the European Commission or the UK Information Commissioner’s Office and/or that may not provide for the same level of data protection as your jurisdiction. As a result, where the personal information that we collect through or in connection with the Services, or that we otherwise collect, is transferred to and Processed outside the EEA or United Kingdom for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA or United Kingdom, including, when required by applicable laws, entering into data transfer agreements using the EU Commission approved Standard Contractual Clauses or other mechanisms that provide an adequate level of protection for your personal information. You may have a right to details of the mechanisms under which your data is transferred outside the EEA or United Kingdom.

Appendix A: Our Legal Bases for Processing Personal Information of European Union Individuals

Payment Data

Processing Purpose(s): To fulfill and pay for your orders.

Our Legal Basis: Performance of a contract between you and us or your employer, and our legitimate interests, namely our interest in the proper administration of our Services.

Inquiry Data

Processing Purpose(s): To respond to your customer service requests, inquiries, and comments.

Our Legal Basis: a)Legitimate interests, namely the proper administration of our Services and business and communications with users, and b) Performance of a contract between you or your employer and us.

Contact Information

Processing Purpose(s): To provide you our newsletters (with your request), to send you marketing communications as mentioned in this Policy, for advertising purposes, Service delivery, and for any other purposes set forth in the “How We Use and Process Your Personal Information Section.”

Our Legal Basis: Where you are a business Customer, the legal basis for this Processing is a) our legitimate interests, namely the marketing of relevant Services to you, as permitted by applicable law, or where you are a direct customer, the legal basis for this Processing is consent; and b) performance of a contract between you and us and/or your employer.

Account Data

Processing Purpose(s): To provide our Services to you and for other purposes mentioned in the “How We Use and Process Your Personal Information” section.

Our Legal Basis: To fulfill our contractual obligations to you or your employer.

Location Data

Processing Purpose(s): To provide our services to you and for other purposes mentioned in the “How We Use and Process Your Personal Information” section

Our Legal Basis: To fulfill our contractual obligations to you or your employer. Where we are collecting location information (including field boundaries and GPS coordinates) from public databases, the lawful basis for this basis is our legitimate interests, namely improvement or development of our Services.

Service Usage and Preference Information

Processing Purpose: To improve or develop our Services, for research and analytics purposes and for and other purposes mentioned in the “How We Use and Process Your Personal Information” section.

Our Legal Basis: Legitimate interests, namely the development, improvement or provision of our Services. Where Service usage information is used for marketing and advertising purposes, the legal basis is consent (where required by applicable laws).

Data Collected From Cookies and Other Tracking Mechanisms

Processing Purpose: To improve or develop our Services, to understand your Service usage and preferences, for advertising purposes including evaluating the success of our advertising campaigns (see Ad Networks section for further details), for research and analytics purposes, and for other purposes set forth in the “Our Use of Cookies and Other Tracking Mechanisms section.”

Our Legal Basis: a) Consent, where required by applicable laws; b) our legitimate interests in improving or developing our Services and understanding the needs and preferences of our Customers and to protect our Services; and c) to fulfill our contractual obligations to you or your employer when such cookies and tracking mechanisms are required for the provision of our Apps.

Additional Information for California Consumers Under CCPA

Under the California Consumer Privacy Act (“CCPA”), we are required to notify residents about the personal information that we collect about them in our capacity as a Controller (referred to as a “business” under the CCPA), whether online or offline and how we handle their personal information. This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA. This section does not cover our collection of data in our capacity as a service provider.

Categories of Personal Information Under the CCPA (Last Updated: September 27, 2022)

While our Processing of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information in the prior 12 months (from the Last Updated date above).

Categories and Sources of Personal Information Collected. In the table below, we identify the categories of personal information (as defined by the CCPA), we have collected about California residents. For more information about the business or commercial purposes for which we Process personal information, please see the How We Use Your Information section above.

Identifiers: Includes direct identifiers, such as name, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers.

Customer Records: Includes personal information, such as name, account name, contact information, employment information, account number, and financial or billing payment information, that individuals provide us in order to purchase or obtain our Services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services.

Commercial Information: Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.

Usage Data: Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our Services, and our marketing emails and online ads.

Geolocation Data: Includes precise location information about a particular farm, individual or device.

Professional information: Includes professional and employment-related information (such as current and former employer(s) and position(s), farms and organizations you are associated with, Business Contact Information and professional memberships).

Inferences: Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to Customers, so that we can better reach them with relevant offers and ads.

Sources of Personal Information. The sources from which we collect personal information are described in the section “Information We Collect About You”

In the table below, we identify the categories of personal information we have disclosed for a business purpose or “sold” as defined by the CCPA, as well as the categories of third parties to whom we may disclose or sell such personal information. We describe the business and commercial purposes for which we may disclose and sell in the “With Whom We Share Your Information” section. Under the CCPA, a “sale” includes disclosing or making available to a third party personal information, in exchange for monetary compensation or other benefits or value. Although we do not disclose personal information in exchange for monetary compensation, we may make certain categories of personal information available in order to receive certain benefits or services, such as when we make browsing information available to third party ad networks (through third party cookies and tracking devices on our Services) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. We may also share personal information within the TAC Group Entities for the purposes mentioned in this Policy.

Categories of Personal Information: Identifiers Do we disclose for a Business Purpose?: Yes Do We Sell?: No Categories of Third Parties to Whom Information is Sold or Disclosed: service providers , TAC Group Entities, business Customer, any other entities mentioned in the “How We Share Your Information” section

Categories of Personal Information: Customer Records Do we disclose for a Business Purpose?: Yes Do We Sell?: No Categories of Third Parties to Whom Information is Sold or Disclosed: service providers , TAC Group Entities, business Customer, any other entities mentioned in the “How We Share Your Information” section

Categories of Personal Information: Commercial Information Do we disclose for a Business Purpose?: Yes Do We Sell?: No Categories of Third Parties to Whom Information is Sold or Disclosed: service providers , TAC Group Entities, business Customer, any other entities mentioned in the “How We Share Your Information” section

Categories of Personal Information: Usage Data Do we disclose for a Business Purpose?: Yes Do We Sell?: Yes, only for advertising networks and data analytics Categories of Third Parties to Whom Information is Sold or Disclosed: service providers , advertising networks, data analytics providers, any other entities mentioned in the “How We Share Your Information” section

Categories of Personal Information: Geolocation Data Do we disclose for a Business Purpose?: Yes Do We Sell?: No Categories of Third Parties to Whom Information is Sold or Disclosed: service providers , TAC Group Entities, any other entities mentioned in the “How We Share Your Information” section

Categories of Personal Information: Professional information Do we disclose for a Business Purpose?: Yes Do We Sell?: No Categories of Third Parties to Whom Information is Sold or Disclosed: service providers , TAC Group Entities, business Customer, any other entities mentioned in the “How We Share Your Information” section

Categories of Personal Information: Inferences Do we disclose for a Business Purpose?: Yes Do We Sell?: Yes, only for advertising networks and data analytics Categories of Third Parties to Whom Information is Sold or Disclosed: service providers , TAC Group Entities, market research firms, advertising networks, data analytics providers, social networks, any other entities mentioned in the “How We Share Your Information” section

California Residents’ Rights. In general, as a California resident, you have the following rights with respect to your personal information:

Do-not-sell (opt-out): you may opt out of sales of your personal information by us, by submitting a request here.

Right of deletion: you may request that we delete the personal information we have collected about you. Some exceptions apply to this request.

Right to know: you may request (up to two times per twelve-month period) and, subject to certain exemptions, to receive a copy of the specific pieces of personal information that we have collected about you in the past twelve months. You also have the right to request that we provide them certain information about how we have handled your personal information in the prior 12 months, including the: categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling your personal information; categories of third parties/with whom we have disclosed or shared your personal information for a business purpose; categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party.

Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests: California residents may submit CCPA requests to opt out of sales, requests to know (access) and requests to delete their personal information through one of the following methods:

Calling us at 1-800-567-0000

By reaching us using the Contact US section below

In some cases, we may request additional information to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.

Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. We do not share your personal information with non-affiliated third parties for their own marketing purposes.

Definitions

Please see the following definitions for the terms used in this Policy:

“Affiliate” means all entities owned or controlled by GRAY S INC Inc.

“Business Contact Information” means the name, title, business address (including business email address), business telephone or fax numbers of an employee of an organization that is collected, used or disclosed for the purpose of communicating with the individual in relation to their employment, business or profession.

“Controller” means the organization that determines the purposes and means of the processing of personal information.

“Customer” means a customer of TAC that is a business, enterprise, or other organization but is not an End User.

“End User” means the representatives or individuals authorized to use the Services by the Customer.

“Processor” means the organization that processes personal information on behalf of the Controller.

“Processing” means the recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, collection, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal information.

“TAC Group Entities” means all Affiliates of GRAY S INC Inc. and the family of companies owned or controlled by TELUS Corporation.

Translated Versions of this Policy

For a version of this Policy for residents in Brazil, please click here.
For a version of this Policy for residents in China, please click here.
For a version of this Policy for residents in Mexico, please click here.
For a version of this Policy for residents in Quebec, please click here.
For a version of this Policy for residents in Russia, please click here.
For a version of this Policy for residents in Slovakia, please click here.
For a version of this Policy for residents in South Korea, please click here.
For a version of this Policy for residents in Taiwan, please click here.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make an inquiry, request or complaint, please contact us at privacy@telusagcg.com. For further contact details, please refer to the list of Controllers.