The Excelsis Group, Exile Editions, and Excelsior Publishing respect the privacy of all of our customers, our e-newsletter subscribers, those who participate in our contests and surveys, and all those who use one, two or all three related three branches of the Site (herinafter referred to as the “Site”) – the Site is administered under the aegis of The Excelsis Group).

Our policy is explained below, under the headings relating to the 10 principles of Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

We reserve the right, at our sole discretion, to change, modify, add, or delete portions of the Privacy Policy at any time, without notice. At the time of any changes to the Privacy Policy, we will post these on all three branches of the Site. We ask that you revisit this page from time to time to review the Privacy Policy in case we have made changes. If you do not agree with the Privacy Policy please exit the Site immediately.

Privacy Policy last updated July 2017

1. Accountability
   We are responsible for the personal information in our possession and we have designated a Privacy Officer with responsibility for our complying with all applicable privacy laws. We inform and train staff on our privacy policies and procedures.

We ship book purchases, process credit card payments, and send e-newsletters in house. But, when we work with third party service providers who carry out services on our behalf (for example managing and hosting data, or if required, any of the above) we disclose your personal information to them only to the extent necessary to enable them to provide these specific services to you. We require these third parties to manage and guard all personal information in accordance with Canadian laws.

We may provide links from the Site to other websites run by third parties. If we have provided links to other websites we make no representations whatsoever about the privacy practices of these websites, and we encourage you to read the privacy policies of any site to which you provide personal information.

2. Purpose of Data Collection
   We will clearly inform you about the specific purpose for which we collect personal information at the point at which we collect it. In most cases, you will be asked to provide personal and account information as appropriate for us to provide service to you.

Examples of specific purposes for which we will collect personal information from you are:

• opening an account
• verifying creditworthiness
• processing a book order
• processing an e-newsletter subscription
• identifying customer preferences
• establishing customer eligibility for special offers or discounts

User Reviews

If you are signed into the Site as a user and post information on the Site in a public area, for example in a user review, that information will be deemed published, public information and will therefore no longer be confidential. The communication of personal and account information in that way means this information can be collected and used by others, and you should assess that risk before doing so. By submitting such communication to the Site you automatically grant The Excelsis Group, Exile Editions, and/or Excelsior Publishing a worldwide, royalty-free, irrevocable, non-exclusive licence to use, distribute, or translate that communication.

Cookies
Our Site uses cookies. A cookie is a small amount of data stored on the hard drive of an individual’s computer that allows us to identify the individual with his or her corresponding data that resides in our database – you can, at any time, remove our cookies from your cache. We use cookies to:

• Collect each Site visitor’s domain name, browser type, and IP address. We collect this information from all visitors to track and evaluate aggregate usage of the Site for analytical purposes, in order to help us improve those services. Such basic Internet traffic statistics are not correlated with any personal information.
• Identify a shopper with his or her cart during a shopping session, to make it easier to order a second time, and to allow subscribers to store passwords if they desire.
• Personalize a visitor’s experience on our Site by alerting him or her to features and information we think may be of interest to them.

If you do not want us to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. Rejecting cookies may affect your ability to use of some of the products and/or services on the Site.

3. Consent
   We will inform you of the purposes for the collection, use, or disclosure of personal data, and we will obtain your consent before or at the time of collection, as well as when a new use is identified.

In seeking your consent we will take into consideration your reasonable expectations as a user of the Site, the circumstances surrounding the collection of the personal information, and the sensitivity of the information involved. We will seek your express consent for use of your personal information whenever possible and in all cases when the personal information is considered sensitive.

We will not attempt to obtain consent by deceptive means.

We will not use or disclose your personal information without your knowledge and consent unless it is permitted or required by law as outlined in PIPEDA.

You may withdraw your consent at any time and we will delete your personal information, subject to legal or contractual restrictions and reasonable notice.

Children’s Privacy
We do not intend to collect or solicit personal information from anyone under the age of sixteen. If you are under the age of sixteen, do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from an individual under the age of sixteen, we will remove that information as quickly as possible.

Parents and legal guardians can withdraw consent to their child’s participation and use of their personal information at any time by contacting us at (WHAT CONTACT TO PUT HERE?)

4. Limits to Collection of Information
   We will not collect personal information indiscriminately nor will we mislead you about our reasons for collecting personal information from you.

1. Limits to Use, Disclosure and Retention of Information
   We will use or disclose your personal information only for the purpose for which it was collected, unless we have your consent, or the use or disclosure is authorized by law.

The information will be kept only as long as necessary to satisfy the purposes for which we collected it.

6. Accuracy
   We will keep your personal information as accurate, complete, and up-to-date as necessary, taking into account the purposes for which it is used.

1. Safeguards
   We will protect your personal information against unauthorized access, disclosure, copying, use, or modification using safeguards appropriate to the sensitivity of the information. These safeguards include technological tools such as passwords, encryption, and firewalls, and organizational controls such as limiting staff access to systems containing personal information on a “need-to-know” basis.
   Transmission of the personal information you provide when you create an online account and place an online order is secured using Secure Socket Layers (SSL) encryption technology, and our service providers operate in compliance with the Payment Card Industry (PCI) Data Security Standard (DSS).
2. Openness
   Information about our specific practices relating to the management of your personal information will be made available to you on request.
3. Individual Access to Information
   Upon request, we will inform you if we have personal information relating to you, give you a copy of that information, and explain how it has been used and/or to whom it has been disclosed. If you find that the information is inaccurate or incomplete you have the right to challenge it and we will amend it as appropriate. In certain circumstances under the law, we will not disclose information to you. Examples of such circumstances are if the information is subject to solicitor-client privilege, or if the information contains confidential commercial information, or if disclosure of the information could harm an individual’s life or security. If we will not disclose information to you we will give you our reasons for not doing so.
4. Contacting us concerning the Policy

If you have a comment or a question about our Privacy Policy, or if you wish to challenge our compliance with the Policy, please contact:

Privacy Officer
The Excelsis Group
144483 Southgate Road 14 – GD
Holstein, ON

N0G 2A0
Canada

Individuals who write to us with a complaint about our compliance with the Policy will receive from the Privacy Officer information about our complaint procedures and other possible avenues of recourse. The Privacy Officer will investigate the complaint, and should the complaint be determined to be justified, the Officer will take appropriate measures, including, if necessary, adjusting our information handling practices and policies.