Privacy Policy

We, Cleo Fashions Inc. (“Cleo”) are firmly committed to protecting the privacy, confidentiality, accuracy and security of our customer’s personal information. We do not collect any personally identifying information about customers unless it has been specifically provided to us by the customer. We will not sell, trade or rent any personal information of our customers to any third parties. If you are under 18 be sure to obtain your parent(s) or guardian(s) permission before you send any personal information to us. We have created this privacy policy in order to demonstrate our firm commitment to protect our customer’s privacy and to answer the following questions:

What personal information may be collected from you as our customer?
How is the personal information used?
With whom may the information be shared?
What choices are available to you regarding collection, use and disclosure of the information?
What kind of security procedures are in place to protect loss, misuse or alteration of information under our control?
How can you correct any inaccuracies in the information?
How long do we keep your personal information?

Our privacy policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information (CAN/CSA-Q30-96) and describes how Cleo subscribes to the following Ten Privacy Principals.

Ten Privacy Principals

Principle 1: Accountability: Cleo is responsible for maintaining and protecting customer personal information under its control. Cleo has formed a Privacy Team comprised of associates who are accountable for Cleo’s compliance with our Ten Privacy Principles.
Principle 2: Identifying purposes: The purpose for collecting personal information from our customer will be identified before the information is collected.
Principle 3: Consent: We shall require the customer’s knowledge and consent for the collection, use or disclosure of their personal information, except where required or permitted by law.
Principle 4: Limiting Collection: Any personal information we collect from our customer, by fair and lawful means, will be limited to only those details necessary for the identified purpose. We will not collect more information than we need to fulfill the purpose identified to our customer.
Principle 5: Limiting Use, Disclosure, and Retention: Our customer’s personal information will not be used or disclosed for purposes other than those for which it was collected, except with the customer’s consent or as required by law. We will keep customer’s personal information only for as long as necessary to fulfill the purpose identified to our customer.
Principle 6: Accuracy: We will keep our customer’s personal information accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Principle 7: Safeguards: Customer’s personal information shall be protected with security measures that are appropriate for the sensitivity level of the information.
Principle 8: Openness: We will provide and make readily available to customers information on our policies, procedures and practices relating to how the customer’s personal information is managed.
Principle 9: Customer Access: Upon request, a customer will be informed of the existence, use, and disclosure of his or her personal information and will be given access to that information. A customer may verify the accuracy and completeness of the information and have it amended as appropriate.
Principle 10: Compliance: A customer may forward any questions or enquiries about compliance with these privacy principles to our Privacy Team Coordinator.

Website Registration – Mailing List Form

Cleo’s optional registration form requires you to provide us with contact information (such as your name, address, email address and telephone number). This contact information may be used to send you information about Cleo, the latest fashion news and advance notice of upcoming in-store sales, events, discounts and promotions and is used to contact you when necessary to answer your questions and to respond to your feedback, responses, etc. This contact information is transferred via secure automatic data transfer to our email service provider who tracks campaign activities and results and provides information about our customers’ needs. Cleo uses contractual or other comparable means to protect customers’ personal information and to make sure that the email service provider uses the information only for these stated purposes. If you would like to be added to or removed from the email lists, you can:

Email Customer Relations at customerservice@cleo.ca
Send standard mail requests to the following postal address:

Cleo Fashions Inc.
Attn: Customer Relations
21 Four Seasons Place, 2nd Floor
Toronto, ON M9B 6J8

Send Us Your Resume

When you send us your resume electronically or by fax or mail, it becomes the property of the Human Resources Department at Cleo. Any data obtained and collected from candidates will be kept strictly confidential and stored in our own records for the sole purpose of filling Cleo job openings and indentifying potential candidates for future Cleo job opportunities.

Website Log Files

Cleo uses URL addresses to analyze trends, administer websites, track users’ movements throughout the website and gather broad demographic information for aggregate use. URL addresses are not however linked to personally identifiable information.

Website Contests

We may occasionally run contests on our websites where visitors are asked for personal information such as name, email addresses or telephone numbers. Participation in our contests is not mandatory. If however, you choose to participate, we may use this contact information to send you information about other contests and about Cleo. This contact information is transferred in a secure online environment to Cleo’s web site development service provider to manage the entries. Cleo uses contractual or other comparable means to protect customers’ personal information and to make sure that the web site development service provider uses the information only for these stated purposes. If you have participated in a past contest but no longer wish to receive information or to be contacted, you have the following options:

Email Customer Relations at customerservice@cleo.ca
Send standard mail requests to the following postal address:

Cleo Fashions Inc.
Attn: Customer Relations
21 Four Seasons Place, 2nd Floor
Toronto, ON M9B 6J8

Store Contests

We may also run contests in our stores where you will complete an entry form providing your personal information such as name, address, telephone number and email address. The personal information you provide is used solely for purposes of the contest and to contact you if you win. After the official draw, all entry forms are destroyed, unless you have otherwise consented to let us use your personal information for another purpose.

Website Postcards

If you elect to use our referral service to inform a friend about our site or product offering, you will be asked to provide the friend’s name and email address. We do not however retain the friend’s name and email address in our database or any other place.

Online Security

We have established security measures appropriate to the sensitivity level of information to protect against unauthorized access, disclosure, inappropriate alteration or misuse of information. To keep our customers’ personal information secure, we use industry-leading Secure Socket Layer (SSL) technology. When you submit personal information on our website it is immediately encrypted.

Cookies

Cookies are small data files stored on your computer to allow information flow. We do not use cookies to store your personal information.

Safeguards

Our employees are required to comply with our Information Security Policy. In addition, all employees, including store employees, are required to abide by the privacy standards we have established. They are also required to work according to ethical behavior standards as set out in our Code of Conduct and to sign a Certificate of Compliance periodically. Unauthorized access to and/or disclosure of customer personal information by an employee of Cleo is strictly prohibited.

Her. Rewards

Our customers become members of this loyalty program by completing an enrollment form at any one of our stores. The personal information collected on this enrollment form is used to provide our customers with rewards based on purchases made. It is also used to communicate regular notice of sales, special incentives, store events and bonuses to our members by direct mail, email or telephone marketing. Personal information is stored on a secure database maintained by our loyalty program service provider. The personal information in this database is used to collect and summarize sales information and buying trends to better understand what our Her. Rewards customers buy and how to communicate with them. We also may use this information to help us explore what new products and services to offer to our Her. Rewards. In order to accomplish this, we sometimes contract trusted outside organizations to analyze the information maintained in the database using contractual or other comparable means designed to protect the privacy of customers’ personal information. They are also prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide.

Changes, Updates, Opt-Out Policy

Cleo strives to keep your personal information as accurate and up-to-date as necessary. We provide you with the opportunity to update personal information you have provided, or, opt-out of receiving communications from us at any time. You have the following options for removing your information from our database or marketing lists, so as not to receive any future communications or offers of services or to update your personal information:

Email Customer Relations at customerservice@cleo.ca
Send standard mail requests to the following postal address:

Cleo Fashions Inc.
Attn: Customer Relations
21 Four Seasons Place, 2nd Floor
Toronto, ON M9B 6J8

Privacy Questions & Concerns

If you have any questions or concerns about our personal information handling practices, please contact our Privacy Team Coordinator using any of the following methods:

Email Customer Relations at customerservice@cleo.ca
Send standard mail requests to the following postal address:

Cleo
Attn: Customer Relations
21 Four Seasons Place, 2nd Floor
Toronto, ON M9B 6J8

Policy Updates

Cleo reserves the right to change or modify this privacy policy and our information handling practices, but we will not do so without posting a modification date.

Retail Concepts & Websites Covered By This Privacy Policy

The provisions and practices set out in our privacy policy apply to all our Canadian retail stores and our websites:

www.cleo.ca

Terms & Conditions

Please read these terms and conditions carefully, because both using the site as well as all sale of merchandise and services offered on this site, are subject to these terms and conditions as may be amended from time to time without prior notice to you. You may wish to check this section each time you use the site, as your continued use of the site signifies your acceptance of revised terms and conditions posted here.

Copyright

The entire content included in this site, including but not limited to text, graphics or code is copyrighted as a collective work and may not be reproduced, published, broadcast, posted, modified, transmitted, displayed, distributed, downloaded or otherwise used without the express written permission of Cleo.

Trademarks

All trademarks, trade names, service marks, service names and intellectual property used in this site, are intellectual property of Cleo Unauthorized use is expressly prohibited. Cleo actively and aggressively enforces its intellectual property rights and all such rights are expressly reserved.

Prohibited/Unlawful Use

You agree not to use this site for any unlawful or prohibited purpose that could cause interference with any other visitor’s use of the site or that can cause the site to be damaged.

Warranty Disclaimer

This site and its content are provided "as is" and without warranties of any kind, whether express or implied. To the fullest extent permissible pursuant to applicable law, Cleo disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose and non-infringement. Cleo does not represent or warrant that the functions contained in the site will be uninterrupted or error-free, that the defects will be corrected, or that this site or the server that makes the site available are free of viruses or other harmful components. Cleo does not make any warrantees or representations regarding the use of the materials in this site in terms of their correctness, accuracy, adequacy, usefulness, timeliness, reliability or otherwise. You agree that accessing and using this site and its content are at your sole risk. Any necessary servicing or repairs of any equipment you use to connect with this site are your full responsibility including costs related to all necessary servicing or repairs. Cleo and/or any third party for whom it is in law responsible in connection with this site, shall not be liable for any direct, special, incidental, consequential, indirect or punitive damages, whether in an action under contract, negligence or any other theory, arising out of or in connection with your access, use or inability to use this site, even if Cleo has been advised of the possibility of such damages.

Limitation Of Liability

Cleo shall not be liable for any special or consequential damages that result from the use of, or the inability to use, the materials on this site or the performance of the merchandise, even if Cleo has been advised of the possibility of such damages.

Information Accuracy

Cleo makes every effort to ensure the information on this site up to date and accurate, however, Cleo makes no warranties or representations regarding the accuracy of such information including but not limited to typographical errors or inaccuracies relating to, merchandise descriptions, pricing and availability and will not be bound thereby. Cleo reserves the right to correct such errors and to update site information at any time without prior notice to you.

Term; Termination

These terms and conditions are applicable to you upon your accessing the site and/or completing the shopping process and may be terminated by Cleo without prior notice at any time, for any reason. Cleo may deny you access to the site at any time, immediately and without prior notice, if in Cleo's sole discretion you fail to comply with any term or condition. The provisions relating to Copyrights, Trademark, Warranty Disclaimer, Limitation of Liability, Indemnification and Miscellaneous, shall survive any termination.

Miscellaneous

Cleo’s failure to insist upon or enforce strict performance of any provision of these terms and conditions shall not be construed as a waiver of any provision or right. Neither the course of conduct between the parties nor trade practice shall act to modify any of these terms and conditions. Cleo may assign its rights and duties to any party at any time without notice to you.

Indemnification

You agree to indemnify, defend and hold harmless Cleo, its officers, directors, employees, agents, licensors, partners, service providers, consultants, representatives and suppliers from and against all losses, expenses, damage and costs, including reasonable legal fees, resulting from your use of or other activity on this site or in connection with any violation of these terms and conditions. In order to purchase through this site you must be the age of majority in your province/territory/state of residence and you must agree to pay for all charges noted on this site as payable by you. All prices set out on this site are in Canadian dollars and charges will be processed in Canadian dollars accordingly. Merchandise purchased from this site may only be ordered or purchased for lawful and personal use and any other non commercial use is not permitted. Cleo reserves the right to limit merchandise quantities.

Third-Party Links

In an attempt to provide increased value to our visitors, Cleo may link to other internet sites operated by third parties. Cleo has no control over these other linked internet sites, all of which are wholly independent from this site and from Cleo and have their own separate privacy and data collection practices, independent of Cleo These linked internet sites are only for your convenience and therefore you access them at your own risk. If you visit any of the linked internet sites, we urge you to review their respective terms and conditions of use as well as their privacy and security policies.

Governing Law

Your use of this site, which includes any merchandise orders placed from this site and these terms and conditions, shall be governed by the laws of the province of Ontario and the laws of Canada applicable therein. The United Nations Convention on Contracts for the International Sale of Goods shall not apply.

Global Sourcing Guidelines

Cleo is concerned about the safety and fair treatment of the workers who manufacture the goods Cleo sells, wherever the workers are located. To this end, Cleo has developed the following global sourcing guidelines, which shall apply worldwide to Cleo’s suppliers. Cleo's guidelines require all of Cleo’s suppliers to respect certain employment standards that Cleo believes should be universal notwithstanding more relaxed standards (if any) which may be imposed by applicable local laws.

In the selection of its suppliers, Cleo works hard to choose reputable business partners who are committed to ethical standards and business practices compatible with those of the Cleo At the very minimum, Cleo expects its suppliers to comply with all legal requirements applicable to the conduct of their business.

Each of the Cleo's suppliers agrees that, by accepting orders from Cleo, it will abide by and implement the terms of these guidelines and require the same from each of its subcontractors. Each of the Cleo's suppliers acknowledges that its failure to honour these guidelines will compel Cleo to re-evaluate, and possibly terminate, its business relationship with such supplier.

Employment Standards

Cleo will only do business with suppliers whose workers are, in all cases, present voluntarily, compensated fairly and allowed the right of free association and who are neither put at risk of physical harm, discriminated against, nor exploited in any way. In particular, it is Cleo's policy that:

Child Labour

Child labour is not permissible. No worker shall be employed under the age of 15, or under the age of completion of compulsory education, or under the minimum age of employment in the country of manufacture, whichever is greater.

Forced Labour

Forced or compulsory labour is not permissible. Employment must always be on a voluntary basis.

Wages & Benefits

Suppliers must compensate their employees fairly by providing wages and benefits that, at very least, comply with legally mandated minimum standards.

Working Hours

Suppliers must maintain reasonable work hours, not exceeding prevailing local standards or any maximum prescribed by applicable laws.

Health & Safety

Suppliers must provide their employees with a safe and healthy work environment, designed to prevent accidents and injury to health arising out of or occurring in the course of work. At the very least, suppliers must comply with all applicable laws and regulations for workplace health and safety and the provisions of these Guidelines.

Discrimination

Employment should be based on ability and not on belief or any other personal characteristics. Cleo will only deal with suppliers who do not practice discrimination in employment, including recruitment, hiring, training, working conditions, job assignments, pay, benefits, promotions, discipline, termination, or retirement on the basis of gender, race, ethnicity, social origin, religion, age, disability, sexual orientation, national origin, or political opinion.

Harassment & Abuse

All employees to be treated with respect and dignity. Cleo will not deal with suppliers whose employees are subjected to physical, sexual, psychological or verbal harassment or abuse.

Freedom Of Association

Suppliers must grant their employees the right to choose to affiliate with legally sanctioned organizations or associations without interference.

Environmental Compliance

Suppliers must comply with all local laws protecting the environment. Cleo encourages its suppliers to conduct business so as to minimize the impact on the environment.

Notice

In order to assure that these guidelines’ contents are available to the workers whose well-being is their object, Cleo also requires its suppliers to post these Guidelines prominently on the premises where goods for the Cleo are manufactured in a location accessible to their workers. Finally, in order to ensure conformity with these global sourcing guidelines, Cleo reserves the right to make periodic, unannounced inspections of its suppliers' facilities.