TG Corporate Holdings Limited
Personal Information Protection Policy for Franchisees and Retail Clients
Last Updated November 9, 2012
TG Corporate Holdings Limited (hereinafter also referred to as “Tommy Gun’s”) is committed to safeguarding the personal information entrusted to us by our Franchisees and Retail Clients. We manage personal information in accordance with Alberta’s Personal Information Protection Act and other applicable laws. This policy outlines the principles and practices we follow in protecting the personal information of our Franchisees and of Retail Clients.
For purposes of this policy, “Franchisee” also includes prospective and former Franchisees, “Retail Client” means customers and third parties dealing with the Store locations and business of those Franchisees, as well as Retail Clients of Stores that may be owned by TG Corporate Holdings Limited subsidiaries that operate retail Stores, “Store” includes a barbershop or combined barbershop and product supply retail business.
This policy applies to TG Corporate Holdings Limited and, except to the extent of the foregoing paragraph, its subsidiaries including TG Franchise Limited and TG Real Estate Limited collectively called “Tommy Gun’s”. This policy also applies to any person providing services on our behalf.
Copies of this policy are available to any Franchisee or Retail Client on request.
What is personal information?
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, educational history, etc., or video images of an individual.
What personal information do we collect?
We collect only the personal information reasonable for the purposes of providing services to Franchisees and Retail Clients, and for the purposes of managing Tommy Gun’s and its franchise business.
From Franchisees we collect personal information needed to:
- evaluate suitability of applicants as a Tommy Gun’s Franchisee
- enter into franchise agreements and contracts
- deliver requested products and services
- provide information on warranties for products and services
- notify Franchisees of upcoming events of interest
- initiate, administer, and terminate our Franchisee – franchisor relationships
- ensure Franchisee compliance with our requirements
- meet regulatory requirements
- manage day to day administrative matters
- provide information on future or additional business opportunities
- provide advice with respect to product placement, layout and merchandising
We also collect personal information so that Tommy Gun’s may manage its franchise business, including, without limitation, to improve its franchise business and brand, monitor Franchisee compliance (such as by ensuring there is no diversion), to manage Tommy Gun’s liability with respect to safety and security, and to ensure compliance with its own obligations to its own suppliers.
- for the purpose of responding to or contacting Retail Clients with respect to their interaction at a Store or with a Franchisee.
- in the normal course of our day to day business operations to the extent that subsidiaries of TG Corporate Holdings Limited own and operate Stores.
We ask for consent to collect, use or disclose Franchisee and Retail Client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may also rely on providing adequate notice, or assume your consent in cases where you volunteer information for an obvious purpose. With respect to personal information of Retail Clients collected by a Franchisee, we rely on the consent obtained by our Franchisees in accessing that personal information.
In cases where we collected personal information before January 1, 2004, we assume your consent to our use and, where applicable, disclosure for the purpose for which the information was collected.
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask you to provide your consent in writing by signing a consent form or by checking a box on a form, electronically by clicking a button, or orally. We will not use your personal information for marketing purposes without your consent, unless otherwise allowed by law.
As Retail Client or Franchisee you may withdraw your consent to the use and disclosure of your personal information at any time, unless the personal information is necessary for us to fulfill our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
We may collect, use or disclose Retail Client or Franchisee personal information without consent only as authorized by law. For example, we might not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.
How do we use and disclose personal information?
We use and disclose Retail Client and Franchisee personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may use Retail Client and Franchisee contact information to deliver goods. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary.
In addition TG Corporate Holdings Limited may access a Franchisee’s video surveillance footage with for purposes of monitoring licensed sales, security and loss prevention, and management of Tommy Gun’s’ liability, and upon request by a Tommy Gun’s Franchisee, in order to provide advice to that Franchisee with respect to product placement, layout and merchandising.
Such footage may capture Retail Clients and employees of Tommy Gun’s Franchisees, and where a Tommy Gun’s location is owned by a subsidiary of TG Corporate Holdings Limited, Retail Clients and employees of that Store.
If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.
How do we safeguard personal information?
We make every reasonable effort to ensure that Franchisee and Retail Client information is accurate and complete. We rely on our Franchisees and Retail Clients to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect client personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. Specific mechanisms include limiting disclosure of personal information to Tommy Gun’s employees that reasonably require it to carry out their functions, physical locks and storage security and implementation of web passwords and IT security systems. When we collect video footage of our Franchisee’s locations, we limit access to certain senior officers of TG Corporate Holdings Limited.
We also use appropriate security measures when destroying Retail Client and Franchisee personal information, including shredding paper records and to the extent reasonably possible, permanently deleting electronic records.
We retain Franchisee and Retail Client personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.
Access to records containing personal information
Franchisees and Retail Clients have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may make a request for access to your personal information by writing to
Michael Hansen General Counsel (Privacy)
#4 – 1890 Cooper Rd, Kelowna, BC, V1Y 8B7
P: 250-869-1639 x 108
Or by sending an email to firstname.lastname@example.org
You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. For personal information collected before January 2004, if we do not have a record of disclosures, we will provide information about any disclosure of your information that is likely to have occurred.
You may also request a correction of an error or omission in your personal information.
We will respond to your request within 30 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.
Questions and complaints
If you have a question or concern about any collection, use or disclosure of personal information by Tommy Gun’s, or about a request for access to your own personal information, please contact in the first instance, at the following:
If you are not satisfied with the response you receive, you may also contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6 Avenue, SW
Calgary, Alberta T2P 3W2
Phone: (403) 297-2728 Toll Free: 1-888-878-4044
E-mail: email@example.com Web site: www.oipc.ab.ca