LAST UPDATED: 26-07-2018
International Refills Company Ltd. and its affiliates, successors and assigns (collectively, “IRC”, “We”, “Us”) are committed to safeguarding any personal data you convey to us, including via our websites (including https://litterlocker.com) and any other website(s) managed, operated and/or administered by or on behalf of IRC (collectively, the “Site”). In line with this commitment, the following is a description of IRC’s security measures, its policies regarding the nature of personal data gathered, its reasons for gathering such data, and the use made of such data. It also describes the choices available to you regarding our use of your personal data and how you can access, update and erase this data.
By visiting the Site or otherwise procuring or using our products or services, including by purchasing products in retail stores or on the Site (where available), posting on our blogs, making other submissions to the Site, or providing us with personal data, you acknowledge that you accept the principles and practices outlined in this privacy notice, and you consent to the collection, storage, use and disclosure of your personal data in accordance with this privacy notice. By contacting us at the coordinates provided in the Contact Us section below, you may change or withdraw your consent at any time, on reasonable notice, subject to any applicable legal or contractual restrictions. We will inform you whether the provision of personal data is a statutory or contractual obligation and the possible consequences if you choose not to provide such personal data to us.
If you provide us with personal data about another person, you represent and warrant to us that you have obtained all necessary consents from that other person to permit us to use that personal data as set forth in this privacy notice. You will be the only person liable in connection with the disclosure of personal data about any such person. Accordingly, you agree to indemnify, defend and hold us harmless from any liability, loss, claims, costs and expenses, including reasonable attorneys’ fees, arising from or related to any unauthorized disclosure of personal data about any such person.
If you have questions or complaints regarding our privacy notice or practices, please Contact Us.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please Contact Us.
We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.
1. IRC AS A BUSINESS
2. DATA COLLECTION AND USE
3. DATA SHARING
4. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA VISITORS ONLY)
5. USER ACCESS AND CHOICE
6. TRACKING TECHNOLOGIES / COOKIES
9. ADDITIONAL DATA
11. CONTACT US
IRC specialises in designing, developing and marketing innovative consumer products. Headquartered in Barbados and with a sister company in Canada, it manufactures cat accessories, and specifically litter disposal products. Our products ease litter maintenance for pet owners. For more information about IRC, please see the About section of our site.
IRC is the controller of your personal data and is responsible for your personal data under applicable data protection law. We collect personal data from you when you use our Site; for example, when you purchase products, register products, create an account, sign up to receive our emails, enter contests, post on our blogs, apply for jobs and make other submissions. We may also collect your personal data from third parties to whom you have provided it (such as financial institutions (where e-commerce is available on the Site) and social networking websites or applications), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. We may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site to our visitors. We also collect your personal data through the use of technologies described at section 5 of this privacy notice.
We may use your personal data to:
• Send you requested product or service information (where e-commerce is available on the Site)
• Send product updates or warranty information (where e-commerce is available on the Site)
• Process orders and transactions (where e-commerce is available on the Site)
• Communicate with you about our products
• Make offers to you • Help us target specific products to you
• Help us develop and improve our Site and tailor it to your interests
• Improve your online shopping experience (where e-commerce is available on the Site)
• Improve our Site and other marketing efforts
• Personalize your experience on our Site through your profile and preferences
• Keep track of and analyze your purchases, transactions, shopping patterns, account activity, payment history, etc. (where e-commerce is available on the Site)
• Process your requests and submissions
• Respond to customer service requests
• Improve our customer service
• Respond to your questions and concerns
• Conduct surveys and analyses for research, statistical and product design and development purposes
• Create aggregate data
• Process your job applications and address other recruitment and employment matters
• Administer promotions and contests
• Protect you and us from error and fraud
• Comply with legal and governmental requirements
• Achieve any other purposes as may be permitted by law from time to time
The “IRC Group” comprises IRC, Angelcare Development Inc., RSCU Europe SAS, Hardenberg&Co Ltd. and their respective affiliates. We share your personal data within the IRC Group so that we can notify you about products, services, rewards and special offers you might enjoy. We may also share your personal data with third parties for the purposes described in this privacy notice. We do not sell your personal data to third parties.
• Service Providers. We may provide your personal data to third parties that provide services to help us with our business activities such as operating our Site, offering customer service, better understanding our Site visitors and otherwise providing services to Site visitors, including (where e-commerce is available on the Site) performing functions such as fulfilling orders, delivering packages and processing payments. These third parties are authorized to use your personal data only as necessary to provide these services to us. A list of our current Group Companies is available here and a list of our current Service Providers and Partners is available here;
Where IRC transfers your personal data to a third party service provider, IRC will use contractual means and other safeguards to ensure that such third party service provider will provide a comparable level of protection while the data is being processed including compliance with this privacy notice and all applicable privacy laws. Contractual provisions and other safeguards are also used to ensure that, where your personal data is transferred, processed or stored outside the European Union, it is given protection similar to the protection set forth in this privacy notice. You agree that persons or entities outside of the European Union to which personal data is transferred may be required to disclose your personal data to any competent governmental authorities, courts or law enforcement or regulatory agencies, pursuant to the laws of their jurisdiction. In addition, you acknowledge and agree that your personal data may be transferred to persons or entities outside Barbados in the event of a crisis or emergency relating to Barbados, the Internet, telecommunications, IRC or the servers where your personal data is usually stored in Canada.
• Legal Disclaimer. We may also disclose your personal data:
⋅as required by law, such as to comply with a subpoena, or similar legal process;
⋅when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
⋅if IRC is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data. In any event, you consent to the transfer of your personal data to any third party that acquires all or substantially all of IRC’s business or its online commerce operations or the Site.
IF YOU CHOOSE TO MAKE ANY OF YOUR PERSONAL DATA OR OTHER DATA PUBLICLY AVAILABLE THROUGH OR IN CONNECTION WITH THE SITE, YOU DO SO AT YOUR OWN RISK.
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person [(e.g. government official authority by law)].
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” heading below.
You may consult, correct, update, delete, amend or request a copy of your personal data that we retain by emailing our customer support at info [at] litterlocker.com or by using the contact details provided under the “Contact Us” heading below. We will respond to your request within 30 days.
We retain personal data of active customers only. For customers with an account, we will retain your personal data for 36 months following your last log-in to your account. For customers who place orders as guests, we will keep your personal data for 6 months after your last purchase. We will keep your data for purposes of direct marketing until you withdraw your consent or if you have not opened an e-mail we have sent you within the last year. With respect to customer correspondence, we will retain your data for 7 days following a telephone conversation or an e-mail and for 12 months for case management. After such time periods, your personal data will be deleted. Notwithstanding the foregoing, we will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
You have a right to erase any of your personal data that we retain at any time, except in the following situations:
• You have an ongoing matter with IRC’s customer service;
• If you are suspected to have or have misused our services within the last four years;
• Where e-commerce is available on the Site:
⋅You have an open order which has not yet been shipped or has partially shipped;
⋅You have an unsettled debt with IRC, regardless of the payment method;
⋅If your debt has been sold to a third party within the last three years or one year for deceased customers;
⋅If your credit application has been rejected within the last three months; or
⋅If you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes.
You have the right to object to processing of your personal data ask us to restrict processing of your personal information or request portability of your personal information. IRC will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or that retention of data is required due to legal claims. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Us” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes. You can opt out from direct marketing by following the instructions in each marketing email, by editing your account settings on the Site or by emailing our customer support at info [at] litterlocker.com or by contacting us using the contact details provided under the “Contact Us” heading below.
You have the right to request that IRC restricts the process and collection of your personal data under the following circumstances:
• If you object to IRC’s legitimate interest in processing and collecting certain of your personal data, IRC shall restrict all processing of such data pending the verification of the legitimate interest;
• If you claim that your personal data is incorrect, IRC must restrict all processing and collection of such data pending the verification of the accuracy of the personal data;
• If the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data;
• If IRC no longer needs the personal data but it is required by you to retain such personal data in order to defend legal claims.
If you consider that IRC processes and collects your personal data in an incorrect way you can contact us by emailing our customer support at info [at] litterlocker.com or by contacting us using the contact details provided under the “Contact Us” heading below.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Your failure to provide certain personal data to IRC may justify IRC’s refusal to process any order for the purchase of products or services sold through the Site or to make available certain features of the Site.
Technologies such as: cookies, beacons, tags and scripts are used by IRC as well as analytics or service providers. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the Site and otherwise on the Internet, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies on an individual as well as aggregated basis.
• Analytics / Log Files. We gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personal data.
• LSOs. We use Local Storage Objects (LSOs) such as HTML 5 to store content information and preferences. Third parties who provide certain features on our Site or display advertising based upon your web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML 5 LSOs.
The security of your personal data is important to us. We follow generally accepted standards and implement appropriate levels of security to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. It may be possible for third parties to overhear, see, intercept or access private communications or transmissions unlawfully. While we strive to protect your personal data, we cannot guarantee its absolute security. Any transmission of personal data is done at your own risk.
If you have any questions about security on our Site, you can Contact Us.
We encourage parents and guardians to supervise their children’s use of the Internet, including our Site.
We do not knowingly collect any personal data from children under the age of 13. Children under the age of 13 should not use this Site or provide us with any personal data without the consent and supervision of their authorized guardian.
• Links to 3rd Party Sites. The Site features various links to other websites. By clicking on one of these links, you leave the Site. IRC does not have any control over the operations of these other websites or their content, and the presence of links on the Site in no way implies any responsibility on the part of IRC. Any personal data you transmit through these third party websites is subject to the policies of these particular websites with regards to the treatment of personal data. As such, we suggest that you pay close attention to these websites’ policies regarding personal data.
• Testimonials. We may display personal testimonials of satisfied customers on our Site in addition to other endorsements and reviews of our products. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can Contact Us.
• Social Media Widgets. Our Site includes social media features, such as the Facebook Like, Twitter, Pinterest, Instagram, Google+, Linkedin and Youtube button and widgets, such as the “Share this” button or interactive plug-ins that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy notice of the host.
• Single Sign-On. When you leave a product review on our site, you may opt to use the “Facebook Connect” or “Google Connect” feature. This service will authenticate your identity and provide you the option to share certain personal data with us such as your name and email address to pre-populate the review form. Services like Facebook Connect and Google Connect give you the option to post information about your activities on this Site to your profile page to share with others within your network.
• Changes To This Notice. We may update this privacy notice periodically to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on this Site or, if you have an account with us, by email sent to the e-mail address specified in your account. We encourage you to review this page from time to time for the latest information on our privacy practices. If at any time you do not agree with our privacy practices, please do not provide us with personal data or use our Site. IF YOU ARE DISSATISFIED WITH THIS PRIVACY NOTICE OR THE SITE, YOUR SOLE REMEDY IS TO CEASE USING THE SITE.
The parties have expressly requested and required that this privacy notice and all other related documents be drawn up in the English language. In the event this privacy notice is available in a language other than English and the English version and such other version diverge, the English language version of this privacy notice shall prevail.
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
International Refills Company Ltd.
#1 Hythe Gardens, Welches, Christ Church
info [at] litterlocker.com
The data controller of your personal information is Virginie Brun.