Unitop Sp. z o.o 

Privacy Policy
Updated as of July 5th, 2021

Introduction

Sesame Snaps®  is a registered trademark of Unitop Sp. z o.o.

The purpose of this Privacy Policy is to explain the privacy practices of Unitop Sp. z o.o. (“Unitop”, “we”, “our” or “us”) in connection with the following digital services (collectively, the “Digital Services”): (i) this website (https://sesamesnaps.ca/) and other websites that we manage or own (individually, the “Website” and collectively the “Websites”), and (iii) any other digital communications or content that we may publish that links to this Privacy Policy, including advertisements that we may place on third-party websites such as social media pages, excluding any software applications made available by third parties on our Website for use on or through computer and mobile devices (the “App(s)”). Please remember, however, that this Privacy Policy only governs our own practices.  If you are interacting with Digital Services through any third-party website(s), application(s) or other service(s), their own privacy policies will govern. The Website may contain links to third-party owned and/or operated websites.  We are not responsible for the privacy practices or the content of such websites. These third-party websites have separate privacy and data collection practices and we have no responsibility or liability relating to them. We recommend you review the privacy policies of these third parties. 

By accessing or using the Digital Services, you are agreeing to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Digital Services or provide us with any of your Personal Information (defined below).  

Types of Information We Collect and Use

Our Digital Services may collect, use, store and transfer different kinds of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you as a particular consumer or device (“Personal Information”), such as:

• Identity Data may include your legal name, age, date of birth, screen name, and profile picture.
• Contact Data includes mailing address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) addresses, your browser type and version, time zone setting and location, geolocation, cookies, carrier information, browser plug-in types and versions, operating system and platform, sensory data (e.g., audio, electronic, visual, or similar information), or other technology on the devices you use to access the Digital Services.
• Usage Data includes information about how you use the Digital Services, such as the session duration, pages served, the source of the request, and the preceding page views.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties (including our brand partners), your communication preferences, and the materials that you have viewed and interacted with.

We also may collect, use, and share “Aggregated Data” such as statistical or demographic data. Aggregated Data could be derived from your Personal Information but is not considered Personal Information as this data will not directly or indirectly reveal your identity.  We may collect, retain, use and share Aggregated Data in any manner without restriction.  However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, citizenship, medical condition, physical or mental disability, marital status, gender, occupation, religious or philosophical beliefs, veteran or military status, sexual orientation, political opinions, criminal history, information about your health, and genetic and biometric data). 

How do we Collect Personal Information? 

Submitted by You: We may collect Personal Information you provide to us, for example, if you:

• Contact us with a question, comment, or request;
• Initiate a search on the Websites or use any of the Digital Services;
• Respond to any promotional and/or other marketing offers, including any offers initiated by us or third-party marketing automation providers;
• Participate in our subscription or newsletter program;
• Respond or leave any feedback or comments to any articles or posts published on our Website; or
• Submit any other content, such as on our social media pages.

Cookies and Similar Automatic Tracking Technology: The Digital Services may use cookies, flash cookies, web beacons, embedded scripts, location-identifying technology or similar technology to collect Personal Information automatically as you use the Digital Services.  These technologies also allow us to collect or interact with Personal Information stored on your device or browser and monitor your usage of the Digital Services.  We may also engage third-party companies to help us collect and track this data (for example Google Analytics).  You may be able to deactivate or opt-out of some of these technologies through your browser settings, device settings, or take other steps, depending on the methods you use to access the Digital Service.  For more information, please click here to read the Network of Advertising Initiative’s recommendations for Opting Out of Internet Advertisements.  Please note that disabling cookies or deleting information contained in cookies or flash cookies may interfere with the performance and features of the Digital Services, including not being able to store your preferences or login information.  (Your browser settings may also allow you to automatically transmit a “Do Not Track” signal to online services you visit.  Note, however, that there is no industry consensus as to what site operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.)

IP Addresses:  An IP address is a number that is automatically assigned to your computer whenever you access the Internet. When you request pages from any Digital Services, we automatically log your IP address.

Third-Party Sources:  In addition to the Personal Information that we may collect directly from your use of the Digital Services, we may have access to other Personal Information from third parties, depending on the privacy policies of those third-party services and the information you have authorized them to share with us.  For example, we may obtain Personal Information from research and analytic companies, marketing partners, public databases, payment processors, mobile carriers, and similar third-party sources.  We may also receive your Personal Information from other sources, such as people that you are in some way connected with, or our own affiliates and representatives.

Location Tracking: Additionally, when you visit our Website, we may collect information about your location when you select your location on the “Where to Buy” section.  This type of information may be used to locate your proximity to nearby gas stations, supermarkets and retail stores, or to identify offers and other location specific items that may be of interest to you. 

Interactive Services: If you post information or otherwise provide feedback and/or personal information by and through the Website, you should be aware that any personally identifiable information that you submit there can be read, collected or used by other users of the Website and/or Digital Services and could be used to send you unsolicited messages or otherwise contact you without your consent or desire. We are not responsible for the personal information that you choose to submit in this manner. Further, by submitting feedback and other material, you: (a) represent and warrant that our use of your submission does not and will not breach any agreement, violate any law or infringe upon any third party’s rights; (b) agree that we are free to use in any manner all or part of the feedback and other material on an unrestricted basis without the obligation to notify, identify or compensate you or anyone else; and (c) grant us all necessary rights, including a waiver of all copyright, trademark, privacy and moral rights, to use all feedback and other material, in whole or in part, or as a derivative work, without any duty by us to anyone whatsoever.

How is the Personal Information that We Collect Used?

We may use Personal Information in a variety of ways, including: 

• To provide you access and use of the Digital Services, including registering you as a subscriber to our exclusive newsletter to hear about deals, special offers and upcoming collections.
• To manage our relationship with you, which includes communicating with you about contests, updates, and changes to our Privacy Policy.
• To administer the Digital Services, including troubleshooting, data analysis, testing, maintenance, support, reporting, and hosting of data. 
• For marketing, promotion and advertising purposes, including conducting analytics, aggregating data, contests, surveys and sweepstakes. For example, email marketing from us and our third-party advertisers and brand partners.
• To use, evaluate, improve or develop our Digital Services.
• To provide customized suggestions, notifications and recommendations to you that you may find interesting.
• To comply with our legal obligations and law enforcement requests.
• To fulfill contractual obligations to third parties, such as our brand partners, service companies, and licensing agreements.
• To permit you to interact with other users or representatives of ours.
• To establish or defend legal claims or protect our rights.
• To detect security incidents, prevent potentially fraudulent, illegal or harmful activities and otherwise enforcing our Privacy Policy.
• To conduct other business analytics, research, planning, reporting or forecasting.
• For any purpose that we disclose to you at the time we collect the Personal Information
• To handle, respond to, or otherwise process any request that you make. 

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Mobile Marketing: Where you submit a mobile telephone number on the Website, if ever, you agree to receive mobile marketing including, but not limited to, SMS text-message based marketing, from us, and from our third party advertisers and marketers (where, and to the extent that, such marketing is permitted by applicable law). As such, notwithstanding that your mobile telephone number may be listed on any municipal, provincial and/or federal Do-Not-Call registries, we, retain the right to contact you via SMS text-message-based marketing in accordance with applicable municipal, provincial and federal laws. Further, you agree that we reserve the right to share, sell, rent, lease and/or otherwise distribute your mobile telephone and other mobile data with/to any third-party for any and all non-marketing uses permitted by this Privacy Policy and applicable law.

How is the Personal Information We Collect Shared? 

Your Personal Information may be shared as follows:

• Brand Partners: We may share aggregated, anonymized customer information with our brand partners and suppliers with whom we have a business relationship, but this information will not contain any personally identifiable information about you. 
• Related Parties: We may disclose your Personal Information to any of our direct or indirect parents, subsidiaries or affiliates, and/or any of our or their respective parents, affiliates, subsidiaries, owners, managers, officers, directors or agents, licensees, and/or any other entity that is in common control with any of the foregoing, whether by beneficial ownership, voting power, or the ability to control or direct the management or policies of any such entity, whether by contract or otherwise. 
• Merger or Acquisition: We may share your Personal Information with a third party who directly or indirectly acquires any ownership interest in us or any of our affiliates, or acquires the Digital Services, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets. 
• Permitted by Law: We may share your Personal Information if: (i) we believe that we are required to do so by law or legal process; (ii) we believe that we are permitted to do so by law or legal process; (iii) to respond to a claim; or (iv) to protect the rights, property, or safety of us, our affiliates, or others. 
• With Your Consent:  We may also share any Personal Information from or about you with any party if you consent to that disclosure.  For example, we may need your consent to share information with a social media platform or other sharing functionality.  
• Public Disclosures: We may make certain Personal Information available publicly if it is reasonably apparent at the time you submitted it that it would be shared or would be publicly available, for example, reviews or customer feedback or photos you share about products or services, social media posts and similar content. 

The third parties with whom we share this Personal Information may use it for their own purposes and in accordance with their own policies.  We are not responsible for their actions.

Security 

We take reasonable steps to help protect your Personal Information under our control. However, data transmitted over the Internet is not completely secure and we cannot guarantee the security of any information that is provided to us.   If you have reason to believe that your interaction with us is not secure, you must immediately notify us of the problem by contacting us (See “Contact Us” below).

Retention, Correction and Deletion

We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  

You may request that we update or correct any of your Personal Information or delete any of your Personal Information.  We will respond to all requests for corrections or deletions in accordance with applicable data protection laws, but we may reject your request if we determine it is unreasonable or not required by law, or if we determine that it could expose us to operational risks or fraud.  We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts or law enforcement agencies in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that jurisdiction to maintain protections on the personal information that are equivalent to those that apply in the jurisdiction in which you live.

Changes to this Privacy Policy 

We may revise this Privacy Policy from time to time, and/or use your Personal Information for new, unanticipated uses not specified in this Privacy Policy. Should we update this Privacy Policy, updated versions of this Privacy Policy will be posted on the Websites. You should review this Privacy Policy periodically so that you can be up to date on our most recent privacy policy and procedures. 

Contacting Us

If you have any questions about this Privacy Policy, the practices of this Website or Unitop, your dealings with our website, or if you want to access, amend, or delete your personal information you can write or email us to submit your request.

Mail:

Unitop Sp. z o.o. 

Ul. Andrzeja Struga 61

Łódź​, ŁÓDZKIE, 90-959

Poland

Attention: Privacy Compliance Officer

Email:

Attention: Privacy Compliance Officer 

odounitop@unitop.com.pl