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PRIVACY POLICY





PRIVACY POLICY FOR CLIENTS

Privacy Policy

This is the privacy policy of Encore Canada, together with its parent,
affiliated and subsidiary companies (“Encore”, “we” or “us”).

How We Protect Your Privacy

The privacy and security of your personal information is very important to us.
We do not share your personal information in ways not disclosed in our privacy
policy or without your informed permission. We value your trust highly and
strive to protect the confidentiality and appropriate use of any personal
information you provide to us. Details are described below.

If there are questions or concerns regarding this statement, please contact:

Encore
Attn: Privacy Office
5100 N. River Road
Suite 300
Schiller Park, IL 60176
Phone: 1.866.698.9514
Email: privacy@encore-us.com



Privacy Policy Structure

Below is a list of the topics covered within this Privacy Policy by heading:

 * Purpose of this Privacy Policy
 * Personally Identifiable Information Encore Collects and Uses
 * Personally Identifiable Information Disclosure
 * Website and Internet Privacy
 * Links to Other Websites
 * Active Information Collection
 * Passive Information Collection
 * Other Uses and Disclosures of Information
 * Data Security
 * Processing of PII for Marketing Purposes
 * Ask Us / Enforcement of this Privacy Policy
 * Changes to this Privacy Policy
 * Acceptance of this Privacy Policy.

 

Purpose of this Privacy Policy

Encore recognizes the importance of protecting your information, including your
personally identifiable information (such as your name, phone number, email
address and other contact information, collectively, “PII”) that you provide to
Encore, that Encore collects about you, that Encore receives from other sources,
and that Encore creates about you. This Privacy Policy sets out our policies
regarding the collection, use and disclosure of your PII, both through our
online and offline operations. This Privacy Policy also explains how you can
exercise your rights in relation to the PII we hold about you and how you can
let us know if you do not wish Encore to use your PII for marketing or
promotional purposes.

The purpose of this Privacy Policy is to tell you how Encore strives to better
serve you by keeping you informed of promotions, products and services, while,
at the same time, safeguarding your PII.

This Privacy Policy is incorporated into, and made part of, Encore’s websites
(the “Encore Sites”).

Personally Identifiable Information Encore Collects

Information you give us:

When you order equipment or services and/or join one of Encore’s programs, we
need to collect certain PII from you in order to provide our services to you and
to improve our services. The service that you choose will determine what
information we collect from you. This information may include, but is not
limited to:

 * Name: We collect your name to provide you services and communications related
   to new services so we can identify you.
 * Signature: We may need your signature in order to approve the purchase of
   goods or services that we offer.
 * Personal or business email address: We collect your email address as our
   primary method of identifying unique customers and users of our goods and
   services.
 * Home or business street address: We collect your business or personal street
   address to send you invoices or information about the goods and services that
   we offer.
 * Phone numbers at which we can contact you: We collect phone numbers so that
   we can reach you related to existing ordered goods or services and future
   needed services.
 * Credit card number: We collect your credit card numbers because we may permit
   you to pay for our goods or services by credit card.
 * Other financial information: We may request certain financial information
   from you for purposes of checking your credit history and receiving payments
   from you.

We may also require certain information from you when you request any of the
following services or equipment: special equipment needs, special service needs,
special commercial terms, or use of a specific offer that you qualify to
receive. For example, if you wish to use an equipment offer that Encore provides
to members of an association/affiliate to which you belong, we may need to
collect information about your membership to verify your qualification for the
offer and provide you with the correct offered services.

You may choose not to provide some of your PII to us, but this may prevent us
from providing our services to you, or limit our ability to provide you with the
level of service that you would otherwise expect from us.

Encore’s websites and services are not directed to or intended for persons under
the age of 18. Encore does not knowingly collect PII from persons under the age
of 18. If you are under the age of 18, please do not provide such information to
us.

Active Information Collection

At various points on the Encore Sites, you might choose to actively provide
certain kinds of information, including PII. The Encore Sites typically will
indicate which information is required and which information is optional at the
information collection point in question. In any case, by submitting information
via an active information collection point at any of the Encore Sites, you
consent to the collection, use, and dissemination of such information in
accordance with this Privacy Policy.

Active information collection points at the Encore Sites may include:

Online Transactions

Encore maintains rigorous standards to protect your PII. We use encryption
technology to ensure the secure transmission of any PII you provide for use
during an onsite transaction. All transactions at our Encore Site are conducted
using 128-bit Secure Sockets Layer (SSL) encryption. SSL is the standard
security technology for establishing an encrypted link between a web server and
a web browser. This link ensures that all data passed between the web server and
browsers remain private and integral. SSL is an industry standard and is used by
millions of websites in the protection of online transactions with customers.
You can easily determine when you are sending data securely by looking at the
web address (URL) in your browser window: the first few letters will change,
from “http” to “https” when you are transmitting information protected by SSL
encryption. The “s” in “https” stands for “secure.”

Email Reply Mechanisms

The Encore Sites may provide you with one or more email mechanisms through which
you may submit questions or comments. Information you provide via such email
mechanisms is typically optional. We may use the information you provide in your
email to respond to your inquiry, and we reserve the right to retain whatever
information you submit in your email, including any PII via the email mechanism.



Question, Comment, and Feedback Forms

The Encore Sites may post a form for you to use in submitting questions,
comments, and other feedback about us, our affiliates, the Encore Sites, or our
affiliates’ products and services, and other topics. We use such feedback
information to improve the Encore Sites, and affiliates’ products and services
as well as for marketing and research purposes. Most information you provide in
such forms is optional, but you will need to provide at least some PII, so that
we may respond to your inquiry.

Information Request Forms

The Encore Sites may include a form that you can use to request information
about us, our affiliates, or our affiliates’ products and services, or to
request catalogs or brochures or price quotes. In addition to asking you to
identify the specific information or materials in which you are interested,
these forms may request, among other things, your PII, so that we may send you
the information or materials you request. These forms may also request certain
information about you to help us better understand your interests and needs.



Surveys and Evaluations

The Encore Sites may ask you to complete optional surveys and evaluations about
us, our affiliates, the Encore Sites, or our affiliates’ products and services,
and other topics. These surveys and evaluations might request PII so that we can
follow up with you. Typically, we use such surveys and evaluations to better
understand our customers and their preferences.

Registration Forms

As access to portions of the Encore Site is restricted to authorized users, you
may be required to complete a registration form. This form may ask you for a
variety of information that will help us to identify you and contact you,
including some PII and your relationship to us. Registration information will be
associated with your username and password, without which you will not be able
to access the restricted portions of the Encore Sites.



Information we collect about you:

When you order equipment or services, we will also record information that
details your order (e.g. where you ordered the equipment or services, where and
when you used the equipment or services, payment arrangements, insurance
preferences and other information related to the equipment or services
personnel).

How we collect information will depend on how you use our services. We may
collect this information directly from you by postal mail, phone, fax, email, at
our offices, upon completion of an application or enrollment form, or through
your use of our Encore Sites or the Internet. To the extent you use our Encore
Sites, we may also collect information about your use of our Encore Sites,
transactional and account information, email and other information related to
communications to our Encore Sites.

Passive Information Collection

The Encore Sites uses various technologies to passively collect information from
you while you are visiting (that is, you do not actively provide this
information). Such technologies allow the Encore Sites to collect a range of
PII, including your Internet Protocol (IP) address (a unique identifier
automatically assigned to your computer when logging onto the Internet), the
type of web browser and operating system you use, the date and time you visit
the Encore Sites, the specific pages you visit on the Encore Sites, and the
address of the website you visited before coming to the Encore Sites. We
typically use such passively collected PII for a variety of purposes, such as to
administer the Encore Sites, customize the Encore Sites to your preferences, and
compile aggregated statistics for marketing and research purposes.



Two types of passive information collection technologies deserve a special
mention:

Cookies

“Cookies” are small text files that store information about your interactions
with a particular website, either temporarily (known as a “temporary” or
“session” cookie, and deleted once you close your browser window) or more
permanently on the hard drive of your computer (known as a “permanent” or
“persistent cookie”). Cookies can make it easier to use a website by allowing
servers to access certain information quickly:

Session cookies can be used to help a user’s browser navigate a website more
smoothly and may show up if the user comes from a website with which the
subsequent website has some relationship (e.g., a website of an affiliated
company) and can give helpful information.

Persistent cookies can be used to customize a website for a user, such as by
storing passwords, preferences, and registration and account information so that
users do not have to re-enter them each time they visit a website.

The Encore Site uses both session/temporary cookies and persistent/permanent
cookies to store information that allows us to offer you better customer service
and to navigate through the Encore Site with ease. To make the Encore Site
easier to use, we combine information collected via cookies with PII. You agree
that we have the right to use both session/temporary cookies and
persistent/permanent in the ways we have described in this privacy policy.

Please note that if you configure your browser to reject cookies, you might not
be able to access important functions or areas of the Encore Site or enjoy
certain conveniences at the Encore Site.

Information we receive from other sources:

We may also collect information about you indirectly through a travel agent,
an account program in which you or your employer participates, through a meeting
planner or other event organizer, or through one of our partner programs, when
you deal with us through those means. Additionally, our affiliates and third
parties may provide us with information about you.


Personally Identifiable Information Use and Disclosure

Usage

The law requires us to only use your PII where specific justifications apply. We
set out the lawful justifications we rely upon to use your PII below. It is
necessary for Encore, affiliated parties and non-affiliated parties to process
your PII:

 * To provide the services and offerings that you request, and to communicate
   with you regarding such services and offerings; and
 * To do all things necessary to administer those services.

We process PII you provide to us for the purposes of the following legitimate
interests of Encore, affiliated and non-affiliated third parties:

 * To research, develop, manage, protect and improve our Encore Sites and
   services;
 * To maintain, develop and improve our service-oriented software and other
   business systems;
 * To analyze data, or to have a third party do so on our behalf; and
 * To conduct direct marketing activities.

We also use your PII information or some discrete part such as your email
address for other Encore marketing and communication purposes.

If you use our Encore Sites, information may also be used to evaluate what
portions of our Encore Sites are visited more often than others, determine where
visitors came from, where they go, and how long they stay on a particular page,
or on the Encore Sites in general.

We may match information collected from you through different means or at
different times, including, for example, information collected online and
offline, and use such information along with information obtained from other
sources, including third parties with whom we have a confidentiality agreement
in place. To do this, it is often necessary to share this information with
carefully selected vendors and business partners we work with, such as companies
that manage accounts, offer affinity, frequent-user, and reward programs, and
companies that perform marketing services and other business operations for us.
For more information see Disclosure below.

Disclosure

You agree that we have the right to disclose to and share your PII with
affiliated and non-affiliated organizations including, for example:

 * To your company or organization if you use our services under a corporate
   or other commercial account;
 * To entities that provide services on our behalf;
 * To your credit card issuer;
 * To credit reporting and fraud checking agencies;
 * To debt collection agencies, if you fail to pay monies owed to us;
 * To government, regulatory and law enforcement agencies where the disclosure
   is required or authorized by law, and otherwise as we believe is necessary or
   appropriate to satisfy any law, regulation or other governmental request, to
   operate our Encore Sites properly, or to protect or defend our rights or the
   rights or well-being of our employees, users or others or if you are involved
   (or are suspected by governmental authorities or our security functions to be
   involved) in any illegal activity, even without a subpoena, warrant or court
   order.
 * Which pages you visit on our Encore Site, to our affiliates and
   approved third party vendors, and venue partners for their use both on our
   behalf and for their own business purposes in connection with Encore
   services.
 * To other non-affiliated third parties, such as entities that provide services
   for or through our Encore Sites or for our business (e.g., advertisers, ad
   servers, content providers, services providers, credit card processors,
   fulfillment services providers, email list hosting companies and distribution
   companies) that use such information on our behalf in a way which is
   consistent with this Privacy Policy. These types of third parties are not
   permitted to use your information for any secondary purposes.

Other Uses and Disclosures of Information

From time to time, our service providers may have access to information you
submit via the Encore Sites to provide operational or other support services for
the Encore Sites (e.g., web hosting or database services). We have put in place
agreements with such service providers to protect against unauthorized uses or
disclosures of such information.

Except as otherwise provided in the “Active Information Collection” section
above, we reserve the right to provide access, or otherwise transfer PII you
submit via the Encore Sites to our contracted third party business partners
(including email delivery services and content providers), affiliates, and
dealers for the purposes described in this Privacy Policy.  We have shared
personal information with our contracted third-party business partners in the
preceding twelve (12) months.  Categories of shared information we generally
provide to contracted third parties typically includes: name, street address,
email address, and phone number.

We have not sold the personal information of adults or minors to any
unaffiliated third parties within the prior twelve (12) months and we will not
do so in the future.

Notwithstanding anything to the contrary in this Privacy Policy or elsewhere on
the Encore Sites, we reserve the right to share or transfer any information,
including PII, you submit via the Encore Sites to another person or company in
connection with the sale, assignment or other transfer of the business of the
Encore Sites and/or Encore (in whole or in part or any of their assets),
including bankruptcy; to respond to law enforcement requests; or where required
by applicable law, statute, regulation, ordinance, subpoena, or court order. By
submitting PII via the Encore Sites, you consent to such disclosures in
accordance with this Privacy Policy.

All transfers of PII, international or otherwise, shall be in compliance with
this Privacy Policy and all applicable laws.

Processing of PII for Marketing Purposes

You have the right to ask Encore not to process your PII for marketing purposes,
either by us or by our third-party providers on our behalf. We will ask you
(before collecting your PII) if we intend to use your PII for such purposes or
if we intend to disclose your PII to any third party for such purposes. You can
exercise your right to prevent such processing by checking certain boxes on the
forms we use to collect your PII. You can also exercise the right at any time by
calling us, sending an email, or by writing to us at the address below:



Encore
Attn: Privacy Office
5100 N. River Road
Suite 300
Schiller Park, IL 60176

Phone: 1.866.698.9514
Email: privacy@encore-us.com

If you subscribe to an Encore mailing list, your name and email address will be
added to the subscribers’ database and you will be sent updates about Encore
activities. If you no longer wish to receive such updates, please click on the
‘Unsubscribe’ link in the emails or contact us at any time by email or by post
(as set out above) and we will remove your details as soon as possible. We may
also provide additional methods for you to let us know whether you would like us
to use and/or disclose your PII for promotional and marketing purposes, such as
by clicking on a checkbox located on the page of our Encore Site on which your
PII is collected, or otherwise made available when you make reservations.

Your option not to receive promotional and marketing material: (a) shall not
preclude us from corresponding with you, by email or otherwise, regarding your
relationship with us (e.g., your account status and activity or our responses to
questions or inquiries you pose to us, confirmations for existing reservations);
(b) shall not preclude us, including our employees, contractors, agents and
other representatives, from accessing and viewing your PII for our internal
business purposes; and (c) shall not preclude us from disclosing your PII as
described in this Privacy Policy for purposes other than sending you promotional
and marketing materials.

Storage of PII

For our customers who are in the European Economic Area (“EEA”), the PII that we
collect from you will be transferred to, and stored at, a destination outside
the EEA. It will also be processed by staff operating outside the EEA who work
for us or for one of our suppliers. This includes staff engaged in, among other
things, the fulfillment of your order, the processing of your payment details
and the provision of support services. By submitting your PII, you agree to this
transfer, storing or processing. Encore will take all steps reasonably necessary
to help safeguard your PII and see that it is treated in accordance with this
privacy policy. All PII you provide to us is stored on our servers which employ
security measures consistent with industry standards.



Data Security

Although we take steps to protect personally identifiable information you
provide via the Encore Sites from loss, misuse, or unauthorized alteration, no
system is 100 percent secure or error-free. Therefore, we do not, and cannot,
guarantee the security or accuracy of the information we collect via the Encore
Site, and you acknowledge that you are assuming the risk in transmitting any
information to us.

It is your responsibility to safeguard any usernames and passwords you use to
access portions of the Encore Site and to notify us if you ever suspect that
these usernames or passwords have been compromised. You acknowledge that you are
solely responsible for any unauthorized use of this Site conducted via your
username or password. We ask you not to share a password with anyone.

Retention Periods

To ensure fair processing, your PII will not be retained by Encore for longer
than necessary in relation to the purposes for which it was originally
collected, or for which it was further processed such as for tax, accounting,
legal, or reporting purposes as may be required by law.

Your Rights

You can exercise your right to access the PII we hold about you, as well as
other rights in relation to the PII we hold about you, by contacting the Privacy
Office. If you make a request relating to any of your rights, Encore will
consider each such request in accordance with all applicable data protection
laws and regulations.

We will need to verify your identity before we can fully respond to a request
and, in some jurisdictions, we are permitted to charge a nominal fee to cover
the administrative costs of providing you with details of the PII we hold about
you. If you are a customer in the EEA, no administration fee will be charged for
considering and/or complying with a request unless the request is deemed to be
excessive in nature.



If you wish to contact us to: (1) inquire about our privacy practices; (2)
provide feedback and comments regarding our privacy practices; or (3) access or
correct your PII we have, contact us as detailed above.

If you are a customer in the EEA, you may be able to exercise the rights below.
If you wish to exercise the rights below in relation to your PII, please submit
a written request to privacy@encore-us.com.

 * Information access
 * Objection to processing of your PII
 * Objection to automated decision-making and profiling
 * Restriction of processing of PII
 * PII rectification
 * PII erasure

If you are a customer in the EEA, you also have the right to lodge a complaint
with a supervisory authority. The supervisory authority in the UK is the
Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or
telephone: +44 (0) 0303 123 113.



Links to Other Websites

Our Encore Sites may contain links or references to other websites outside of
our control, and the privacy policies of these websites are separate from our
Encore Sites and may differ from our own. Please be aware that we have no
control over such websites and our privacy policy does not apply to such
websites. We advise that you check the privacy policies of such websites before
disclosing any PII via such websites.



Ask Us / Enforcement of this Privacy Policy

If at any time you have questions, comments, or concerns about this
Privacy Policy, or the information practices of this Site, please contact us in
one of the following ways:



Mail to:

Encore
Attn: Privacy Office
5100 N. River Road
Suite 300
Schiller Park, IL 60176
Phone: 1.866.698.9514
Email: privacy@encore-us.com



Changes to this Privacy Policy

Encore reserves the right, at our discretion, to change, modify, add, or remove
portions from this Privacy Policy at any time so visitors are encouraged to
review this Privacy Policy at the inception of each session. If Encore makes a
material change to our practices with regard to PII that would negatively affect
the privacy and/or security of your PII, Encore will notify you in advance and
give you a reasonable period of time to object to any such changes.

Acceptance of this Privacy Policy

By using our Encore Sites, or otherwise providing your PII to us, you signify
your acceptance of our Privacy Policy. If you do not agree to this policy,
please do not use the Encore Sites or provide any PII to us.

This Privacy Policy was last revised December 2019753109




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