Privacy Policy


  • INTRODUCTION

Your privacy is of utmost importance to us – and we commit to protecting your privacy by complying with this policy.

This Privacy Statement describes how P&P Optica, Inc. (“PPO”, “we” “our”) collects, uses, discloses and protects personal information that we collect through our services, website and other digital properties that link to this Privacy Statement (collectively, the “Service”), as well as through our social media, marketing activities, and other activities described in this Privacy Policy. In addition, this policy describes rights you may have in respect of your personal information under applicable law.  For purposes of this privacy policy, “personal information” is information from which you can be identified, could potentially be identified, or which relates to you or a specific individual.  This includes your name, business or personal mailing address, business or personal email address, business or personal telephone number, Internet protocol (IP) address used to connect your computer to the Internet, and any other identifier we may use to contact you

California notice at collection:  Please see the State law privacy rights section for important information about the personal information we collect about California residents and their privacy rights. 

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. 

The PPO Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies that apply to the collection and use of your personal data. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit. This policy does not apply to data collected by third parties through any application or link that may be accessible from or on the PPO Website.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, please do not use the Website or our Service. By accessing or using the Website or the Service, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy below). 

  • INFORMATION WE COLLECT ABOUT YOU
      1. We collect and use several types of information from and about you, including:
        1. Personal information that we can reasonably use to directly or indirectly identify you. 
        2. Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature. Since this cannot be used to identify you, this is not personal information.
        3. Usage Data, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access or use our Service and usage details.
        4. Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
  • HOW WE COLLECT INFORMATION ABOUT YOU
      1. We use different methods to collect your information, including through:
        1. Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise. 
        2. Automated technologies or interactions, as you use our Service. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • Information You Provide to Us 
        1. The information we collect directly from you through our Service may include:
          1. Information that you provide by filling in forms. This includes information and material provided, posted, or uploaded at the time of requesting information or services. We may also ask you for information when you report a problem with our Service.
          2. Records and copies of your correspondence (including email addresses), if you contact us.
          3. Your responses to surveys that we might ask you to complete for research purposes.
  • Information We Collect Through Cookies and Other Automatic Data Collection Technologies  
        1. As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
          1. Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
          2. Information about your computer and internet connection, including your IP address, operating system, and browser type.
        2. We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
        3. The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or that we receive from third parties. This information helps us to improve our Service and to deliver a better and more personalized service, including by enabling us to:
          1. Estimate our audience size and usage patterns.
          2. Store information about your preferences, allowing us to customize our Website according to your individual interests.
          3. Recognize you when you return to our Website.
        4. The technologies we use for this automatic data collection may include:
  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
          1. Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit PPO, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 
      2. Information We Collect from Third-Parties
        1. We may receive personal information about you from our partners, vendors or other business relationships that we use to provide or improve the Service. This information may include, for example, much of the same information set forth above such as name, business name, IP address, location, number of visits, time and date of visits, pages visited, etc. Even if received from a third party, we protect your information as set forth in this policy 
  • HOW WE USE YOUR INFORMATION
      1. We use information that we collect about you or that you provide to us, including any personal information:
        1. To provide our Service (including the PPO Website) to you.
        2. To provide you with information, products, or services that you request from us.
        3. To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
        4. To improve our Website, products or services, marketing, or customer relationships and experiences.
        5. To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
        6. In any other way we may describe when you provide the information.
        7. For any other purpose with your consent.
  • DISCLOSURE OF YOUR INFORMATION
      1. Because it is neither personal information nor capable of identifying any individual, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
      2. We may disclose personal information that we collect or that you provide as described in this privacy policy:
        1. In accordance with applicable law, 
        2. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PPO’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PPO about our customers and users is among the assets transferred.
        3. To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
        4. To fulfill the purpose for which you provide it. 
        5. For any other purpose disclosed by us when you provide the information.
        6. With your consent.
      3. We may also disclose your personal information:
        1. To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
        2. To enforce any of our rights or apply our terms of use and other agreements, including for billing and collection purposes.
        3. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PPO, our customers, or others.
      4. We do not sell or share your data — regardless of how “sell” or “share” is defined under applicable law.
  • TRANSFERRING YOUR PERSONAL INFORMATION
  • We are headquartered in Canada and may use service providers that also operate in Canada or in other countries outside the country in which you reside. Therefore, your personal information may be transferred to countries which may not provide the same level of data protection as guaranteed under the applicable data protection laws of the country in which you reside (e.g., the EU GDPR). For all such transfers we ensure that these countries are either considered adequate according to the applicable data protection law (e.g., by way of an adequacy decision of the EU commission) or that appropriate safeguards are in place such as standard contractual clauses. If you want to obtain a copy of these safeguards, you can contact us at [email protected]. We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business  and the Service (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
      1. By submitting your personal information or using our Service, you consent to this transfer, storage, or processing as set forth herein and in a manner consistent with applicable law.
  • DATA SECURITY
      1. The security of your personal information is very important to us. We maintain appropriate physical, organizational, and technological safeguards against unauthorized access, unauthorized disclosure, theft, or misuse appropriate to the sensitivity of such Personal Information.
      2. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service or other products, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 
      3. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Website or Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. 
  • DATA RETENTION
      1. Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. 
  •      CHILDREN UNDER THE AGE OF 13
      1. The Service is not intended for children under 13 years of age and we will not intentionally or knowingly collect any information of any individual under age 13. If you are under 13, do not use or provide any information on this Website, or provide any information about yourself to us by any other means, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].
  • European Data Protection Rights 

We will only process your personal information if and to the extent we have a legal basis for doing so. The following are the legal bases that we rely upon to justify our processing: 

  • Your consent – We will process your personal information with your prior consent, which you may give directly to us, or to other organizations (e.g., our third party data providers). 
  • Performance of a contract – We will process your personal information where necessary to enter into, or for the performance of a contract. For example, we process your personal information to: 
    • provide, operate and improve the Service and our business; 
    • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages; 
    • provide support for the Service, and respond to your requests, questions and feedback; 
    • enforce the terms and conditions that govern the Service. 
  • Legitimate interests – We will process your personal information for the purposes of our legitimate interests, or the legitimate interests of third parties we work with, as long as these interests are not overridden by your interest or fundamental rights and freedoms. For example, we may process your personal information for the following legitimate interests: 
    • providing and operating our Service; 
    • carrying out direct marketing activities, unless consent is required in which case, we would obtain consent; 
    • analyzing and improving the Service and our business; 
    • creating aggregated, de-identified or other anonymous data from personal information we collect; 
    • preventing, identifying, investigating and detecting fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; 
    • auditing our internal processes for compliance with legal and contractual requirements and internal policies; 
    • disclosing or transferring personal information in the event of a business transaction (or negotiations and due diligence for such transactions) involving a corporate, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interest). 

In all of the above cases, we carefully strike a balance between our legitimate business interests and your interests or fundamental rights. For more information in the individual case, you can contact our Privacy Officer. 

  • Compliance with legal obligations – We will process your personal information if it is necessary to comply with legal obligations. For example, we may process your personal information to: 
    • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; 
    • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims). 

When PPO processes your personal data and such processing is subject to European Union (EU GDPR) or United Kingdom (UK GDPR, UK Data Protection Act 2018) data protection law, depending on the applicable law, you may have certain rights with respect to that data, namely: 

  • Right of Access. You have the right to request confirmation as to whether or not we process your personal data. If so, you also have the right to request access to the personal and further information as specified under the applicable data protection law. 
  • Right to Rectification. You have the right to request that we correct inaccurate or incomplete personal data that we store about you. 
  • Right to Erasure. Under certain conditions, you have the right to request that we erase the personal data we may hold about you. 
  • Right to Data Portability. Under certain conditions, you have the right to receive the personal data, which you have provided us in a structured, commonly used, and machine-readable format and to transfer those data to another controller. 
  • Right to Withdraw Your Consent. If the processing of personal data is based on your consent, you can withdraw consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal. 
  • Right to Object. Under certain conditions, you have the right to object to the processing of your personal data, in case the processing is based on legitimate interests or in case your personal data are processed for direct marketing purposes. 
  • Right to Restriction of Processing. Under certain conditions, you have the right to request the restriction of the processing of your personal data. 

To exercise any of these rights (if they are available to you under the applicable law), please contact us using the information below. 

When another entity is the data controller, PPO will refer your request to the third-party data controller and/or provide you with the information you need to contact the data controller directly. 

You can also lodge a complaint with a competent data protection supervisory authority if you consider that the processing of your personal data infringes the applicable data protection law. 

To the extent permitted by applicable law, we reserve the right to charge a fee or decline requests: (i) that are unreasonable or excessive; (ii) where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person; or (iii) where we are unable to authenticate you as the person to whom the data relates. Also, please note that we often need to retain certain data for reasons such as recordkeeping and/or to complete any transaction that you began prior to requesting a change or deletion of your data. 

When you contact PPO about exercising any of the rights available to you under the applicable data protection law, PPO will ask you for information to verify your identity. In your request, please clearly identify the personal data that is the subject of your inquiry. We will comply with your request as soon as reasonably practicable and within any time frames prescribed by law. 

  •           CHANGES TO OUR PRIVACY POLICY
      1. We reserve the right to amend this Privacy Policy for any or no reason, at any time, and from time to time in accordance with the terms of this Privacy Policy. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
      2. Your continued access to or use of the Website after any such amendment constitutes your acceptance of the Privacy Policy as then amended. We include the date this Privacy Policy was last amended at the top of this page. 
  • CONTACT INFORMATION     
    1. We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our privacy practices or compliance with this policy please contact our Privacy Officer using the contact information listed below:

[email protected]

680A Davenport Road, 

Waterloo, Ontario, Canada 

N2V 2C3

  • State law privacy rights 

Scope. This section applies to residents of California. For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the state in which you reside, but does not include information exempted from such laws.  

Your privacy rights. You have the rights listed below. 

  • Right to know. You can request confirmation about whether or not we have collected your personal information, and information about the categories of personal information that we have collected, the categories of sources from which we collected personal information, the business or commercial purpose for collecting, sharing and/or selling personal information, the categories of third parties with whom we share personal information, the categories of personal information that we sold, shared or disclosed for a business purpose, and the categories of third parties with whom the personal information was sold, shared or disclosed for a business purpose. 
  • Right to access. You can request a copy of certain personal information that we have collected about you. 
  • Right to delete. You can ask us to delete certain personal information that we maintain about you. 
  • Right to correct.  You can ask us to correct inaccurate personal information that we have collected about you. 
  • Right to nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the privacy laws of the state where you reside. 

How to exercise your rights.  You can exercise the privacy rights described above by submitting a request to [email protected].  The rights described above are subject to limits and exemptions and in certain cases we may decline your request as permitted by law.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.  You can ask to appeal any denial of your request in the same manner that you may submit the request. 

Verification of identity. We may need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your residency. To verify your identity, we may require you to log into your Service account if you have one, provide information we can match against information we may have collected from you previously, confirm your request using the email address we have on file, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.   

Authorized agents.  If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.  If you are a California resident, your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable California law.  

Additional information for California residents.  The following describes our practices currently and during the past 12 months: 

  • Sensitive personal information. We do not use or disclose sensitive personal information for restricted purposes that California residents have a right to limit under the CCPA (Cal. Civ. Code §1798.140).
  • Deidentified data. We do not attempt to reidentify deidentified information that we derive from personal information, except that we may do so to test whether our deidentification processes comply with applicable law. 
  • Sources and purposes. We collect all categories of personal information from the sources and use them for the business purposes described in the How we use your personal information section above,  and we disclose them for the business purposes described in the How we share your personal information  section above.