Privacy Policy

This Privacy Policy explains how Varity Ventures (“Varity Ventures“, “we”, “us”) collects, uses, discloses and protects personal information when you visit www.varityventures.ca (the “Website”) or contact us, and when we provide shared services to the businesses in our group. It is written to meet Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial privacy laws, and the privacy laws of U.S. states that give their residents privacy rights.

Buying from one of our businesses? Each of our online stores and products has its own privacy policy on its own website (see our Legal Notice for the list). That policy explains how the business handles your orders and account, and it applies to those purchases. This policy covers the Website and our role as the parent company.

1. Summary

We do not sell your personal information, and we do not share it for cross-context behavioural (targeted) advertising.

2. Who is responsible

Varity Ventures, a sole proprietorship [registration], with its registered office at:

We have appointed a privacy officer who is responsible for our compliance with this policy and with privacy law: Privacy Officer, support@varityventures.ca.

3. Personal information we collect

Information you give us

• When you contact us (contact form, email or phone): your name, email address, the topic and content of your message, and anything you choose to include.
• When you work with us as a supplier, partner, service provider or contractor: names, job titles, business contact details and the information needed to manage the relationship, pay invoices and meet our tax obligations.
• When you make a privacy request: the information needed to identify you and answer your request.

Information collected automatically

• Technical data: IP address, browser and device type, pages visited, referring page, date and time. Our hosting provider records this in server logs to deliver and secure the Website.
• Cookies: a cookie that remembers your cookie choice. See our Cookie Policy.

Information about customers of our businesses

As the parent company, we provide shared services to our businesses, such as accounting, technology, customer support and fraud prevention. When we do, we handle their customers’ personal information on their behalf, only for those purposes, and under the privacy policy of the business you dealt with.

We do not intentionally collect sensitive information (such as health, financial account or government identification numbers) through the Website. Please do not send it to us through the contact form.

4. How we use personal information

We use personal information only for purposes a reasonable person would consider appropriate in the circumstances, and that we identify before or when we collect it:

• to answer your questions and requests, and keep a record of them;
• to manage our relationships with suppliers, partners and service providers;
• to provide shared services to our businesses;
• to operate, maintain and protect the Website, including detecting spam, fraud and security incidents;
• to meet legal, tax, accounting and regulatory obligations, and to establish, exercise or defend legal claims.

We do not use your information for a new purpose without telling you and, where the law requires, obtaining your consent. We do not make decisions about you based solely on automated processing.

5. Consent

By contacting us or using the Website, you consent to the collection, use and disclosure of your personal information as described in this policy. We ask for express consent where the law requires it – for example before optional cookies are placed. You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our privacy officer or using the cookie settings at the bottom of every page. We will tell you about the likely consequences of withdrawing.

6. When we share personal information

We share personal information only as follows:

• Service providers that work for us – such as website hosting, email, IT support, accounting and professional advisers. They may use the information only to provide their services to us, must protect it, and are bound by contract to do so.
• Businesses in our group, when needed to answer your request (for example, a question about an order from one of our stores) or to provide shared services.
• Legal reasons: when required or permitted by law, for example to respond to a court order or a lawful request from authorities, to protect our rights, property or safety or those of others, or to prevent fraud.
• Business transactions: if all or part of our business is sold, merged or reorganised, personal information may be disclosed to the parties involved, under confidentiality obligations and only as needed for the transaction.

We do not sell personal information, we do not share it for cross-context behavioural advertising, and we have not done so in the past 12 months.

7. Where your information is stored

Your personal information is stored and processed in Canada and the United States. Some of our service providers may process it in other countries. When information is located outside your province or country, it is subject to the laws there and may be accessible to the courts, law enforcement and national security authorities of that jurisdiction. We use contracts and other measures to give it a comparable level of protection.

8. How long we keep it

We keep personal information only as long as needed for the purposes described in this policy, or as required by law (for example, Canadian tax law generally requires us to keep business records for six years). The retention periods are listed in the summary above. When we no longer need personal information, we securely delete it or anonymise it. If we used your information to make a decision about you, we keep it long enough for you to be able to ask for access to it.

9. How we protect it

We protect personal information with safeguards appropriate to its sensitivity, including encrypted connections (HTTPS), access limited to people who need it, strong passwords and multi-factor authentication for our systems, reputable service providers and regular updates. No method of transmission or storage is completely secure, but we work to protect your information and review our safeguards regularly.

If a privacy breach creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada (and other authorities where required) as soon as feasible, and we keep a record of every breach as the law requires.

10. Your rights in Canada

Subject to limited exceptions set out in the law, you have the right to:

• know whether we hold personal information about you, and get access to it and to an account of how it has been used and to whom it has been disclosed;
• ask us to correct information that is inaccurate or incomplete;
• withdraw your consent, subject to legal or contractual restrictions;
• complain to us, and to the privacy regulator, about how we handle your information.

We answer requests within 30 days. Access to your personal information is free of charge; we will tell you in advance if a request requires a reasonable fee for copying or transcription.

11. Your rights in the United States

Depending on the U.S. state where you live (for example California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia), you may have the right to:

• know and access the personal information we have collected about you, including the categories, sources, purposes and recipients;
• delete personal information we collected from you;
• correct inaccurate personal information;
• receive a copy of your personal information in a portable format;
• opt out of the sale of personal information, its sharing for targeted advertising, and profiling that produces legal or similarly significant effects;
• limit the use of sensitive personal information (we do not use sensitive personal information to infer characteristics about you);
• not be discriminated against for exercising these rights;
• appeal our decision on your request. If we deny your appeal, you may contact your state Attorney General.

To exercise these rights, use our contact form (topic “Privacy request”) or email support@varityventures.ca. We will confirm receipt within 10 business days and respond within 45 days (which we may extend once by 45 days when reasonably necessary, after telling you). We verify your identity by matching the information you give us with the information we hold. You may use an authorized agent; we will ask for proof that the agent is authorized and may ask you to confirm your identity directly.

12. Notice at collection for California and other U.S. residents

In the past 12 months we have collected the following categories of personal information:

We have not sold or shared (for cross-context behavioural advertising) any of these categories in the past 12 months, and we do not knowingly sell or share personal information of consumers under 16. We keep each category for the periods listed in section 1.

13. Global Privacy Control and Do Not Track

We honour the Global Privacy Control (GPC) signal: if your browser sends it, we treat it as a request to opt out of the sale or sharing of your personal information and keep optional cookies off. Because there is no common standard for “Do Not Track” signals, we do not respond to them separately – but GPC covers the same choice.

14. Children

The Website is not directed to children, and we do not knowingly collect personal information from children under 13 (or under the age of digital consent where you live). If you believe a child has given us personal information, please contact us and we will delete it.

15. Electronic messages

We do not send commercial electronic messages (such as newsletters or promotions) without your consent, as required by Canada’s Anti-Spam Legislation (CASL) and the U.S. CAN-SPAM Act. Every such message identifies us and includes a free and easy way to unsubscribe, which we honour within 10 business days. Replies to your own questions are not marketing messages.

16. Changes to this policy

We may update this policy to reflect changes in our practices or the law. The date at the top shows when it was last updated. If we make significant changes, we will tell you on the Website before they take effect and, where required, ask for your consent.

17. Contact us and complaints

For questions, requests or complaints about privacy, contact our privacy officer:

Privacy Officer
Varity Ventures
2453 Coho Way, Oakville, Ontario, L6M0G7, Canada
Email: support@varityventures.ca

We will investigate every complaint and, if it is justified, take appropriate measures. If you are not satisfied with our answer, you may contact:

• the Office of the Privacy Commissioner of Canada – priv.gc.ca, 1-800-282-1376;
• for California residents, the California Privacy Protection Agency – cppa.ca.gov; residents of other U.S. states may contact their state Attorney General.