Our Commitment to Privacy
Introduction and General Concepts
a) Personal Information
For the purposes of this Policy, “personal information” means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number, social insurance number, sex, income and family status. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. We will only collect, use or disclose personal information in accordance with this Policy, or in accordance with laws applicable to the collection, use and disclosure of your personal information by us (“Applicable Privacy Laws”).
b) Non-Personal Information
On the other hand, “non-personal information” is any type of information other than personal information, and is excluded from this Policy. For example, non-personal information would include business information, or information that enables an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. Non-personal information also includes information that is anonymous or not about an identifiable information, such as web browsing information (such as the domain used to access the Site, or the type and version of device, browser or operating system being used to access the Site), or aggregate information that anonymizes the underlying data (like the number of visitors, what pages users visit, average time spent on the Site or on various parts of the Site). We will collect, use or disclose non-personal information in accordance with our ordinary business practices, but always in accordance with any applicable laws. This Policy, however, only covers our collection, use and disclosure of personal information.
The Information We Collect
As indicated above, we collect two types of information through our Site: personal information and non-personal information. The types of information we collect about you will depend on the nature of your interaction with us or the Site.
a) Information we collect from you:
We may collect the following personal information from you:
- contact information such as name, email address, mailing address, phone number; or
- any other information that you voluntarily enter or submit, including personal information, into any postings, fields, forms, or otherwise submitted to us by email.
b) Information we automatically collect
We may also automatically gather information about your computer such as your IP address, browser type, referring/exit pages, operating system, as well as which aspects of our performance metric indicators available with our technology or our licensees’ products you prefer using. Some of this may be personal information, but in typical cases it is non-personal information. Specific examples follow:
- IP, etc.—When using our Site, we may collect the Internet Protocol (IP) address of your computer, the IP address of your Internet Site Provider, the date and time you access our Site, the Internet address of the Site from which you linked directly to our Site, the operating system you are using, the sections of our Site you visit, the Site pages read and images viewed, and the content you download from the Site. This information is used for Site and system administration purposes, and to improve the Site.
- Cookies—We may use “cookies”, a technology that installs a small amount of information on a user’s computer to permit the Site to recognize future visits using that computer. Cookies enhance the convenience and use of the Site. For example, the information provided through cookies is used to recognize you as a previous user of the Site, to offer personalized content and information for your use, to track your activity at the Site, to respond to your needs, and to otherwise facilitate your Site experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Site and your ability to access certain features of the Site or engage in transactions through the Site.
- Tracking Information—We may use web beacons or single-pixel gif tags to compile tracking information reports regarding Site user demographics, Site traffic patterns, Site purchases and other aggregated Site statistics, and these beacons may be used in our emails to determine which emails and links have been used by recipients. We may then provide these reports to advertisers and others. None of the tracking information in these reports can be connected to the identities or other personal information of individual users. For our own research purposes we may link tracking information with personal information voluntarily provided by Site users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy.
How We Use The Information We Collect
We may use your personal information, in combination with your non-personal information, for a variety of business purposes, for example to:
a) send you requested information;
b) send new product or service information;
c) respond to customer service requests;
d) send you a newsletter;
e) carry out contests or promotions;
f) send you marketing communications;
g) respond to your questions and concerns;
h) improve our services, products and marketing efforts;
i) conduct research and analysis; or
j) to enforce our Terms.
Disclosure and Sharing of Your Information
We will share your personal information with third parties only in the ways that are described in this Policy. We will not sell your personal information to third parties, however the use of our Site necessarily requires some sharing or disclosure of your personal information.
a) Third Party Processors
We may provide your personal information to companies that provide services to help us with the Site such as web hosting providers, payment processors, product shipping providers, fulfilment agencies, or customer service agencies (“Third Party Processors”). These Third Party Processors are authorized to use your personal information only as necessary to provide these services to us, and in a manner consistent with this Policy. We have selected Third Party Processors who will only use your information in compliance with this Policy, but they may have their own specific policies regarding the collection and use of personal information. We will use commercially reasonable efforts to identify such Third Party Processors when we are collecting your personal information, as well as providing links to the relevant privacy policies that may apply.
b) Further Disclosures
We may also disclose your personal information (i) as required by law such as to comply with a subpoena, or similar legal process, (ii) 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, or (iii) to any other third party with your prior consent to do so.
c) Third Party Links
Our Site may contain links to other websites or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting another website or Internet resource. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect and use your personal information.
Our Commitment to Data Security
We use reasonable industry standard technology to keep information that you submit to us secure. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect online. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee the security of any information transmitted to us and you do so at your own risk.
We will collect, use, or disclose your personal information only with your knowledge and consent, except where required or permitted by Applicable Privacy Laws. When you choose to provide us with your personal information you consent to the use of your personal information as identified in this Policy and as may be further identified at the time of collection.
d) Express Consent
Sometimes you will be asked to give your express consent to our collection, use or disclosure of personal information – for example, by being asked to check a box to indicate your consent to receive marketing communications in compliance with Canada’s anti-spam laws.
e) Implied Consent
Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, when you provide us with your address through a form or email seeking information, you provide us with implied consent to use that address in order to respond to your request.
f) Withdrawing Your Consent
You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure or your personal information. We will accommodate your request subject to legal and contractual restrictions. The most common way of indicating this withdrawal of consent is (i) by changing your privacy preferences to the extent such functionality is made available through the Site, or (ii) deleting your account with the Site and stopping use of the Site. In other situations, you may be able to opt out of the use of your personal information. For example, if you have “opted in” or subscribed to one of our mailing lists, we will always provide you the opportunity to “opt out” or unsubscribe. For example, if you receive emails from us, we will provide a link in the email which you can use to unsubscribe from that mailing list, or you may contact us at firstname.lastname@example.org.
You may also choose not to provide us with your personal information. However, if you make this choice we may not be able to provide you with the Site, or information that you have requested.
Use of Third Party Opt-in Lists
With respect to Sofina Foods Inc.’s use of third party opt-in lists, Sofina Foods Inc. may enter into co-branding arrangements with other companies, and if so, an opt-in question may be present for contact from these organizations as well. The opt-in features are specific to each organization, but you should never receive e-mail from these organizations unless you have indicated that it is acceptable. All e-mail from Sofina Foods Inc., or from co-brand partners who gain your permission to send you commercial e-mail, will include an opportunity to opt-out of future communications.
Requests for Access to and Correction of Personal Information
Applicable Privacy Laws allow individuals, to varying degrees, the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:
- identification of personal information under our custody or control;
- information about how personal information under our control may be or has been used by us; and
- the names of any individuals and organizations to which the individual’s personal information has been disclosed.
We will respond to requests within the time allowed by Applicable Privacy Laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.
In certain exceptional circumstances, we may not be able to provide access to certain personal information Sofina holds about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
Removal of Your Information
We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.