Privacy Policy
Last Revised: January 22, 2024
Effective Date: January 2024
We, LBMX Inc. (“LBMX,” “we,” or “us”), are committed to protecting the privacy and security of personal information and to transparency about how we use personal information (also known as personal data). This Privacy Policy sets forth our policies and practices for collecting and using personal information regarding any of our services that link to this Privacy Policy, including our website and any of our services, such as Document Center, Solution Center, Supply Cloud, LBMX My Marketplace, or LBMX Connection (“Services”). This Privacy Policy does not address our use of personal information outside the context of these Services.
For purposes of this Privacy Policy, we regard personal information as any information that relates to an identified person or reasonably identifiable person.
Within the context of the Services, this Privacy Policy explains how we use and disclose personal information. It also discusses how you can control certain uses and disclosure of your personal information. We will update this Privacy Policy from time-to-time, or as our privacy practices change, to ensure it accurately describes how we use your information. When we do so, we will update the dates above. We recommend that you review this Privacy Policy from time-to-time for the latest information. If we change our practices in a material way, we will provide appropriate notice to you, usually through an e-mail message or through a banner or pop-up within our Services.
If you have any questions regarding this Privacy Policy or our use of your information, please contact us using one of the methods detailed below.
1. How We Use And Share Personal Information
We limit the collection and processing of personal information to that which we need for our business purposes, as explained in the following table and the text that follows it.
| Categories of Individuals | Categories of personal information | Purposes | Methods of collection | Categories of third-party recipients (see below) |
| LBMX website users | Device, usage, and activity information
Interest and demographic information Non-precise location information |
Service analysis, security, and administration | Directly from individual
Indirectly by observing individuals’ activities or behavior From network advertisers and analytics providers |
Network advertisersAnalytics providers |
| Individuals who request a demo of our products | Name, title, company affiliation
Business contact information Any other notes voluntarily provided |
To arrange for a demo of our products
Marketing |
Directly from individual | None |
| Individuals who consent to receive commercial and educational e-mail messages from LBMX | Email address | To provide the requested messages | Directly from individual | Email marketing campaign managers |
| Customers who use Document Center, Solution Center, Supply Cloud, LBMX My Marketplace, or LBMX Connection Services | Name and contact information, including company affiliation
Device, usage, and activity information Access credentials (including usernames and passwords) Non-precise location information ERP system information (optional) Other volunteered information or digital assets |
Personalization
Service analysis, security, and administration |
Directly from individualIndirectly by monitoring individuals’ activities or behavior | None |
| Customers who use the payment features of our website | Name and contact information, including company affiliationAccess credentials (including usernames and passwords)
Payment information, including credit card account or bank account and routing information |
To process payments | Directly from individual | Payment processors |
| LBMX Marketing Event Attendees | Name, title, company affiliation
Business contact information Any other notes voluntarily provided |
Marketing | Directly from individual | None |
| Individuals who send us feedback or other correspondence | Sender name and address
Contents of feedback or other correspondence |
To respond to the feedback or other correspondence | Directly from individual | None |
Please be aware that we use third-party tracking technologies to share information with third parties for analytics and network advertising purposes, as described in the table above.
At present, we do not collect or process personal information considered to be “Sensitive Information,” “Sensitive Personal Information,” or “special category data” in connection with our Services.
2. Disclosure And Sharing
In addition to the sharing with the third parties described in the table above, we may also share your personal information with:
- Service providers. We share your personal information with third parties that provide services to us. We engage these kinds of third parties with contracts that require them to use your personal information only for the purpose of delivering the services for which we have engaged the third-party and as required by law. These kinds of third parties provide business, professional, administrative, or technical support functions for us, such as payment processing, billing, data storage, quality assurance, and marketing.
- Legal compliance recipients. We disclose personal information to the courts, the government, law enforcement agencies, litigants, and similar recipients when required by law.
- Successors. We may disclose personal information associated with a part of our business to a buyer, potential buyer, or other successor to our business.
We also may disclose personal information with third parties with your consent or at your direction.
Because no consensus has emerged on how to process a web browser’s “do not track” signal, we do not currently take any action in response to the signal. We also do not process the Global Privacy Control signal and do not presently fall within the scope of any legal requirement to do so.
3. Security, Quality, And Retention
We use reasonable administrative, technical, and physical safeguards to protect personal information in our possession from misuse, interference, loss, unauthorized access, unauthorized modification, or unauthorized disclosure. While we make every reasonable effort to help ensure the integrity and security of our network and systems, you should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be completely secure, accurate, complete, or current.
We also take reasonable steps so that the personal information we collect is sufficiently accurate, up-to-date, and complete for the purposes for which we process or disclose the personal information.
We retain personal information for as long as is necessary for the purposes for which we use it, or for so long as required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when we determine how long to retain personal information:
- Retention periods established under applicable law;
- Industry best practices;
- Whether the purpose of processing is reasonably likely to justify further processing;
- Risks to individual privacy in continued processing;
- Applicable data protection impact assessment;
- Information systems design considerations/limitations; and
- The costs associated with continued processing, retention, and deletion.
4. International Orders And Users
Please be aware that your personal information will be stored and processed in Canada, where our servers are located. If we transfer personal information to Canada from another jurisdiction, we will do so in a way that complies with applicable legal requirements.
5. Children’s Privacy
We are very concerned about the safety of children using the Internet. We do not knowingly collect any personal information from those under the age of 16.
If we discover (or are informed) that we have collected personal information from a visitor under the age of 16, we will promptly delete such information.
6. California Rights Regarding Disclosures For Direct Marketing
California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, entitles California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not presently make any such disclosures. Any other inquiries regarding personal information sharing with third parties may be directed to us at the contact information set forth below.
If you live in the United States of America, depending on the law in the State where you live, you may have certain rights regarding your personal information under the law. To exercise your rights, please submit a request by contacting us through any of the means outlined below.
Your rights may include the following:
- The right to opt-out of the use of personal information for targeted advertising, personal information sales, or profiling resulting in significant consequences;
- The right to confirm whether we process your personal information and to access a copy (from which we may, for security purposes, exclude certain personal information), including a copy that is in a portable data format;
- The right to the correction of inaccurate personal information;
- The right to the deletion of your personal information; and
- The right to appeal the action we take in response to any request to exercise these rights.
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.
Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legally authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You may also appeal the decision we make on your request by using the contact information below. When you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law.
If you live in Canada, you have certain rights regarding your personal information under the law. To exercise your rights, please submit a request by contacting us through any of the means outlined below.
Your rights may include the following:
- The right to learn about the personal information we hold about you;
- The right to learn how we obtained your personal information and how we have disclosed it;
- The right to access your personal information in a cost-effective way;
- The right to the correction of errors or incompleteness in your personal information (and to have us provide notice of such correction to any third parties to which we have disclosed your personal information); and
- The right to ask us to note a dispute about your personal information in our files and to advise third parties where appropriate.
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. If there will be a cost associated with your request, we will make every effort to minimize such cost and we will contact you to confirm that you wish to proceed with your request.
Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legally authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You may also appeal the decision we make on your request by using the contact information below. If you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law.
If you live in Australia or New Zealand, you have certain rights regarding your personal information under the law. To exercise your rights, please submit a request by contacting us through any of the means outlined below.
Your rights may include the following:
- The right to access your personal information in a reasonable and practicable way;
- The right to the correction of errors or incompleteness in your personal information (and to have us provide notice of such correction to any third parties to which we have disclosed your personal information); and
- The right to attach a statement to your personal information if we decline to make a correction you request.
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. If there will be a cost associated with your request, we will make every effort to minimize such cost and contact you to confirm that you wish to proceed with your request.
Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legally authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You may also appeal the decision we make on your request by using the contact information below. If you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law.
If you live in the European Economic Area (EEA) or the United Kingdom (UK), you may have the following rights regarding your personal data:
- Access/Data Export. You may have a right to access the personal data we process and to request it in a common portable format of our choice.
- Rectification. You may request that we correct any personal data that you believe is inaccurate.
- Deletion. You may request that we delete your personal data. We may delete your data entirely, or we may anonymize or aggregate your information so that it no longer reasonably identifies you.
- Restriction of Further Processing. You may request that we restrict the processing of personal data under certain circumstances. For example, you may make this request if you object to our use of your personal data for particular legitimate business interests.
- Objection. You may have the right under applicable law to object to any processing of personal data based on our legitimate interests. We may not be required to cease or limit processing based solely on that objection, and we may continue processing where our interests in processing are appropriately balanced against individuals’ privacy interests. You also have the right to lodge a complaint with a supervisory authority. In addition to the general objection right, you may have the right to object to processing:
- For profiling purposes;
- For direct marketing purposes (we will cease processing upon your objection); and
- Involving automated decision making with legal or similarly significant effects (if any).
Individuals living in the UK and EEA are also entitled to the following information about the legal bases for the processing described in sections 1-2, above.
| Categories of individuals | Categories of personal data | Legal bases |
| LBMX website users | Device, usage, and activity information
Interest and demographic information Non-precise location information |
Our legitimate interests |
| Individuals who request a demo of our products | Name, title, company affiliation
Business contact information Any other notes voluntarily provided |
Your consent
Our legitimate interests |
| Individuals who consent to receive commercial and educational email messages from LBMX | Email address | Your consent |
| Customers who use Document Center, Solution Center, Supply Cloud, LBMX My Marketplace, or LBMX Connection Services | Name and contact information, including company affiliation
Device, usage, and activity information Access credentials (including usernames and passwords) Non-precise location information ERP system information (optional) Other volunteered information or digital assets |
Processing is necessary for the performance of a contract to which the data subject is a party
Our legitimate interests Processing is necessary for compliance with a legal obligation that we are subject to |
| Customers who supply business bank account information for Automated Clearing House (ACH) remittance | Business bank account information | Processing is necessary for the performance of a contract to which the data subject is a party
Our legitimate interests Processing is necessary for compliance with a legal obligation that we are subject to |
| Customers who use the payment features of our website | Name and contact information, including company affiliation
Access credentials (including usernames and passwords) Payment information |
Our legitimate interests
Processing is necessary for compliance with a legal obligation that we are subject to Processing is necessary for the performance of a contract to which the data subject is a party |
| LBMX Event Attendees | Name, title, company affiliation
Business contact information Any other notes voluntarily provided |
Your consent
Our legitimate interests |
| Individuals who send us feedback or other correspondence | Sender name and address
Contents of feedback or other correspondence |
Your consent
Our legitimate interests Processing is necessary for the performance of a contract to which the data subject is a party |
If our processing of your personal data is based on your consent, you may withdraw your consent by contacting us using the information below.
If you are dissatisfied with the decision we make on your request, you may appeal the decision by using the contact information below. If you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law. You also have the right to lodge a complaint with a supervisory authority.
11. Contacting Us
To exercise your rights or for other privacy-related inquiries,
please contact us at:
By email: info@LBMX.com
By postal mail at:
LBMX Headquarters
Attention: Privacy
400 – 148 Fullarton Street
London, Ontario, N6A 5P3, Canada