Privacy Policy

Last Updated: June 29, 2018

Belletrist LLC (“Belletrist”, “we”, “us” or “our”) is committed to protecting the privacy and security of your information. This privacy policy (“Policy”) describes how we collect, use and disclose your personal information and how this personal information can be consulted and corrected when necessary. This Policy also explains how cookies are used on our Website.

By visiting www.belletrist.com (“Website”), contacting us or agreeing to receive emails from Belletrist, you accept the terms and conditions of this Policy. This Policy does not extend to websites operated by third parties. Belletrist is therefore not liable for their privacy policies, procedures and practices.

Collection and Use Of Personal Information

The term “personal information” means any information relating to an identified or identifiable natural person. We collect your personal information in several ways, including when you visit our Website, contact us by telephone or by email, sign-up to receive promotional email or other communications from Belletrist, post on our social media accounts, etc. Depending on the circumstances, personal information may include your name, email address or any other information identifying you.

The legal bases for our processing of personal information are primarily that the processing is necessary for providing the Website and that the processing is carried out in our legitimate interests, which are further explained below. We may also process personal information upon your consent, asking for it as appropriate.

Visiting our Website: We collect the Internet Protocol (“IP”) addresses of visitors to our Website and other information about your visit, such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.

Email and Other Communications: We may obtain your consent to send you email and other communications about products, services, promotions or events that may be of interest to you. You can opt-out of receiving our promotional messages by doing one of the following:

  • If you have received an email, you can follow the opt-out or "unsubscribe" instructions provided in your email.
  • You can always request to be unsubscribed by contacting us through the “Contact” page on our Website or using the contact information set out below.

Contact Us: When you contact us with a comment, question or complaint, you may be asked to provide personal information (such as your name or email address) along with any additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service.

Disclosure of Personal Information

Our policy is that we do not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein. When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organisational measures.

Service Provider Arrangements: We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf. For example, we may use service providers to operate certain features or send email or other communications. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.

Sale of Business: We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Belletrist, as part of a corporate reorganization of Creative Labs Management Inc., or in connection with a stock sale or other change in corporate control.

Legal: Belletrist and our Canadian, US and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by applicable Canadian, US or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims, or as otherwise permitted by law.

Cookies: Our Website and Ads may use a technology called “cookies”. A cookie is a tiny element of data that our Website can send to your browser, which is stored on your hard drive so we may later be able to recognize your computer or other device while you interact with our Ads or our Website. Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of their respective features.

We use Google Analytics to help us gather and analyze information about the areas that you visit on the Website to evaluate and improve the customer experience and the convenience of the Website, and to help us evaluate some of the specific information related to your Website visits. To opt-out of Google Analytics’ tracking of your Website visit across all websites, Google makes a tool available that you can install in your browser.

Security of Personal Information

We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. We have implemented measures designed to help protect personal information in our custody and control. We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

Data Transfer

Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Website, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of the United States, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Policy and, if applicable, we will comply with the General Data Protection Regulation (“GDPR”) requirements providing adequate protection for the transfer of personal information from the EU/EEA to third country.

Rights regarding your Personal Information

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Under the GDPR, you may be entitled to specific provisions, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate; (vi) the right to data portability of personal data concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection at: ec.europa.eu/justice/data-protection/index_en.htm

Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be posted on this Website. If we make material changes to this Privacy Policy, we will notify you by posting a notice on the front page of this Website. We strongly encourage you to please refer to this Privacy Policy for the latest information about our personal information practices.

Children's Privacy

The Website is not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Website at any time or in any manner. If we learn that personal information has been collected via the Website from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided personal information, then you may alert us as set forth in the “Contact” section and request that we delete that child’s personal information from our systems.

Contact

If you have any questions or comments about this Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers, our Privacy Officer can be reached by email at hi@belletrist.com.

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