Last Updated: June 30, 2020
Protecting Your Privacy
- Meaning of Personal Information
- Collecting and Using Personal Information
- Releasing Personal Information
- Protecting Personal Information
- Providing Personal Information Access and Accuracy
- Why We Ask for Your Personal Information
- How We Obtain Your Consent
- When We Release Your Personal Information
- Withdrawal of Consent
- Visiting Our Information Sites
- Flash – Local Shared Object
- Email Comments, Questions or Responses
- Responding to Contest Or Surveys
- Addressing Your Concerns
- California Consumer Privacy Act Notice
Our Commitment to Privacy
1. Meaning of Personal Information
2. Collecting and Using Personal Information
Either before or when we collect personal information about you, we will explain how we intend to use it. We will limit the personal information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your personal information for any other purpose.
3. Releasing Personal Information
We may provide your personal information to other persons in situations where:
- We have your consent;
- The other parties are our suppliers or agents who assist us in serving you, for the same purpose for which we collected it;
- We are required or permitted to do so by law or applicable regulators and self-regulatory organizations; and
- Transfers of a business are involved.
4. Protecting Personal Information
We will protect your personal information with appropriate safeguards and security measures. We will retain your personal information only for the time it is required for the purposes we explain.
We will protect your personal information with appropriate safeguards and security measures. We have thorough security standards to protect our systems and your personal information against unauthorized access and use. When we provide personal information in response to a legal inquiry or order, we ensure that the order is valid and we disclose only the personal information that is legally required. All employees of Nature’s Path are familiar with the procedures that must be taken to safeguard customer personal information. And to us, protecting the confidentiality of your personal information is more than a procedure – it’s part of our job. It is specified in our employment agreements and regularly confirmed in writing. We audit our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate to the sensitivity of the personal information. We retain your personal information only as long as it is required for the reasons it was collected. The length of time we retain personal information varies depending on the product or service and the nature of the personal information. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient personal information to respond to any issue that may arise at a later date. When your personal information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form. We ensure that your personal information is stored securely. [From time to time we may store personal information outside of Canada where it may be subject to lawful access requests in the jurisdiction in question.]
5. Providing Personal Information Access and Accuracy
We will give you access to the personal information we retain about you subject to certain statutory limitations. We will respond to your requests within the timelines prescribed by the applicable privacy legislation. We will make every reasonable effort to keep your personal information accurate and up to date.
Having accurate personal information about you enables us to give you the best possible service and minimize the possibility that out of date personal information may be used to make a decision which impacts you. We have policies and procedures to help us maintain the accuracy of your personal information. For most updates, we rely on you for personal information. You can help by keeping us informed of any changes, such as if you move or change telephone numbers. If you find any errors in our personal information about you, let us know and we will make the corrections immediately, and make sure they are conveyed to anyone we may have misinformed. For personal information that remains in dispute, we will note your opinion in the file.
Why We Ask for Your Personal Information:
We ask you for personal information to establish and serve you as our customer. At the time you begin a relationship with us and during the course of our relationship, we may collect personal information about you. We obtain most of our personal information about you directly from you. The personal information we ask for depends on which product or service you want.
The purposes for which we collect, use and disclose your personal information include:
- Providing services to you;
- Communicating with you by e-mail as described below;
- For administration of contests or surveys as described below; and
- How We Obtain Your Consent:
It is important to understand the different ways that we may obtain your consent to collect, use, disclose and share your personal information. Depending on the situation and the sensitivity of the personal information, we may obtain your consent in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain products or services from us. We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required, and we will clearly indicate when this is the case.
When We Release Your Personal Information:
We do not sell or rent customer lists or personal information to others. However, we may release your personal information to parties outside Nature’s Path in certain circumstances, which include:
- With your consent;
- For servicing purposes;
- When required or permitted to do so by law or applicable regulators and self-regulatory organizations; and
- Transfers of a business.
Withdrawal of Consent:
We will explain your options of refusing or withdrawing consent to the collection, use or release of your personal information, and, given reasonable notice, we will record and respect your choices. In most cases you are free to refuse or withdraw your consent at any time. You may do so by contacting us at +1 (866) 880-7284. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent and record your choices.
7. Visiting Our Information Sites
When you go directly to the information portion of our websites and move from page to page, read pages or download content onto your computer, we learn which pages are visited, what content is downloaded, and the address of websites that you visited immediately before coming to our websites. However, none of this is associated with you as an individual. It is measured only in aggregate.
We use this information to find out how many people visit our websites and which sections of the sites are visited most frequently. This helps us to know what type of personal information is most useful to our website visitors so that we can improve our websites and make it easier for our website visitors to access personal information. We record the statistical information on the numbers of visitors to our websites, but no personal information about you in particular will be kept or used.
A cookie is a small file containing certain pieces of personal information that a website creates when you visit the site. It can track how and when you use a site, which site you visited immediately before, and it can store that personal information about you.
There are two common types of cookies, “session cookies” and “persistent cookies”. Session cookies store personal information only for the length of time that you are connected to a website – they are not written onto your hard drive. Once you leave the website, the originator of the cookie no longer has the personal information that was contained on it.
Nature’s Path uses session cookies as an additional security feature for its online services. For example, when you login to any web service and are authenticated through your login ID and password, a cookie will store the identification number of your browser. Throughout your session, the cookie acts as a type of digital signature to identify your current session to the web server.
We also use session cookies to track your visits within our site. We use that information to determine the type of personal information that you are looking for in our site and to improve our site. We may use this data for system administration and to report aggregate information to our stakeholders. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. This means that your session may be tracked, but you will not be identified.
We use information about the site you visited immediately prior to our site to assess the viability of links to our site that we have created on third party sites.
The personal information stored in “persistent cookies” is written onto your hard drive and remains there until the expiry date of the cookie. Nature’s Path uses persistent cookies to store non-sensitive personal information that you are aware of and have agreed to. We may link the information we store in cookies to any personally identifiable information you submit while on our website. For example, if you choose the option on our login screen to remember your Nature’s Path account, the system will remember and automatically input your user name each time you use the service from that personal computer.
We also employ persistent cookies, in order to provide you with a more comfortable online experience. A persistent cookie is placed on your computer’s hard drive to remember your language preference and ensure you are always presented with the appropriate language. We also employ a persistent cookie to ensure that any online targeted offer which you have already responded to is not presented again each time you login to our Internet banking site. When you submit an application online for a product or service, we may also collect non-personal information, such as city, province and postal code in order to better serve our customers.
We use personal information about your computer, such as IP Address and Browser type. The primary method of collecting this personal information is through a persistent cookie which is added to your computer. The personal information is collected to assist us in authenticating you and your computer. All persistent cookies used by Nature’s Path are encrypted for additional security.
Currently, most browsers do not distinguish between session cookies and persistent cookies. For certain of our web services to operate, your browser must be set to accept cookies. If you are concerned about having your browser enabled to accept cookies while you are surfing other websites, we recommend that you enable your browser to notify you when it is receiving a cookie. This gives you the ability of accepting or rejecting any cookie presented by the web server you are visiting. Most Internet browsers will allow you to delete cookies from your computer hard drive. You should refer to your browser instructions or help screen to learn more about these functions.
9. Flash – Local Shared Object
Local shared objects, sometimes referred to as “Flash cookies”, are data files that a website creates when you visit the site. Shared objects are most often used to enhance your web-browsing experience.
A local shared object is like a browser cookie, except that it can also store data more complex than simple text. Shared objects, by themselves, can’t do anything to or with the data on your computer. More importantly, shared objects cannot access or remember your email address or other personal information unless you willingly provide such personal information. For more information about Flash, please visit www.adobe.com.
10. Email Comments, Questions or Responses
When you send us an email or when you ask us to respond to you by email, we learn your exact email address and any personal information you have included in the email.
We use your email address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. We will not sell your email address to anyone outside Nature’s Path. We may use your email address to send you information about offers on products and services that we believe may be of interest to you. If you don’t want us to contact you by email with offers on products and services, you may tell us so at any time.
If you have asked us to put you on an email mailing list to provide you with certain information on a regular basis, or if we send you information about our offers on products and services by email, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each email and on the site where you signed up).
Remember that email sent over the Internet is generally unencrypted. If Nature’s Path requests that you transmit confidential personal information to us over the Internet when filling out an application online, we ensure that such transmission is encrypted. We recommend that you use caution when forwarding free-format email messages to us and that you do not include confidential personal information in those messages, as they are not encrypted.
We will never send email messages to customers requesting confidential personal information such as passwords or account numbers. Please do not act on any such emails as you may compromise your banking personal information by following links to a counterfeit Internet site(s).
11. Responding to Contests or Surveys
When you submit your response to a survey question or enter one of our contests, we learn your answer or any opinions or personal information that you volunteer. In a contest we will use your personal information for the purpose of awarding a prize. For a survey, we may use your submission to come up with the survey results, and we may publish those results in aggregate on our websites. We may also use your response to improve our products or services. Based on your participation in either, we may forward information about our offers on products and services that we believe may be of interest to you.
12. Addressing Your Concerns
If you have any questions, concerns or problems about privacy, confidentiality or how a request for personal information was handled, we encourage you to let us know, and you can take the following actions. If you choose to mail, fax or email us, please include your full name, address and telephone number. Contact us in one of the following ways:
Telephone: +1 (866) 880-7284
Nature’s Path Foods, Inc.
9100 Van Horne Way
Richmond, BC V6X 1W3
We’ll work hard to provide an acceptable solution but if you are not satisfied, a Manager will become involved in the resolution of your problem or concern.
14. California Consumer Privacy Act Notice
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), Nature’s Path Foods, Inc., our affiliates, and our family of brands that includes Nature’s Path, EnviroKidz, Love Crunch and Que Pasa (collectively, “Nature’s Path,” “we” or “us”) are providing the following details regarding the categories of Personal Information that we collect, use and disclose about California residents. This CCPA Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.
Sources of Personal Information
We collect Personal Information from:
- Our interactions with you, such as when you interact with our websites or other online services we provide, give us feedback, participate in any of our surveys, contests or other promotions, link your social media account to your account with us, or contact customer support; and
- Our affiliates, publicly available online sources, joint business partners, and third-party advertising and market research partners.
Collection and Disclosure of Personal Information
The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.
|Categories of Personal Information||Disclosed to Which Categories of Third Parties for Operational Business Purposes|
|Identifiers, such as name, contact information, IP address and other online identifiers||Our affiliates; trusted third-party service providers; joint business partners; third-party sponsors of sweepstakes, contests and similar promotions|
|Personal information, as defined in the California customer records law, such as name and contact information||Our affiliates; trusted third-party service providers; joint business partners; third-party sponsors of sweepstakes, contests and similar promotions|
|Characteristics of protected classifications under California or federal law, such as age and gender||Our affiliates; trusted third-party service providers|
|Commercial information, such as transaction information and purchase history||Our affiliates; trusted third-party service providers; third parties, to permit them to send you marketing communications, consistent with your choices|
|Internet or network activity information, such as browsing history and interactions with our website||Our affiliates; trusted third-party service providers; joint business partners; third-party sponsors of sweepstakes, contests and similar promotions|
|Geolocation data, such as device location and approximate location derived from IP address||Our affiliates; trusted third-party service providers|
|Audio, electronic, visual and similar information, such as photographs and audio and video recordings||Our affiliates; trusted third-party service providers|
|Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, behaviour and characteristics||Our affiliates; trusted third-party service providers|
Use of Personal Information
We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information to:
- Fulfill your requests and respond to your inquiries;
- Develop, improve, repair, and maintain our products and services;
- Personalize, advertise, and market our products and services;
- Conduct research, analytics, and data analysis;
- Administer contests, surveys and other promotions;
- Maintain our property and our records, and undertake quality and safety assurance measures;
- Conduct risk and security control and monitoring, and detect and prevent fraud;
- Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;
- Carry out corporate transactions, such as mergers, joint ventures, or acquisitions; and
- Comply with law, legal process, and internal policies, and exercise and defend legal claims.
We do not sell and have not sold Personal Information in the preceding 12 months, as “sale” is defined in the CCPA. We do not sell the Personal Information of minors under 16 years of age.
Individual Rights and Requests
If you are a California resident, you may request that we:
- Disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting (if applicable) Personal Information about you; and
- The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
- Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us at firstname.lastname@example.org or +1 (866) 880-7284. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email, state of residency and/or mailing address, in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable:
- Proof of your registration with the California Secretary of State to conduct business in California;
- A power of attorney from the California resident pursuant to Probate Code sections 4000-4465;
- Written permission that the California resident has authorized you to make a request on the resident’s behalf. This permission must be signed (via physical or e-signature) by the California resident.
If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4000-4465, we may also require the resident to:
- Provide you with a written permission signed by the resident to make the request on the resident’s behalf;
- Verify the resident’s own identity directly with us;
- Directly confirm with us that the resident provided you permission to submit the request.