FRESHENOPT Inc. WEBSITES PRIVACY POLICY
FreshenOPT®-Effective Date: July 2019
I. PURPOSE AND SCOPE
FreshenOPT and certain of its Affiliates ("FreshenOPT Group") has created this Privacy Policy ("Privacy Policy") in order to demonstrate our firm commitment to your privacy. "Affiliates" means, with respect to any entity, any other entity which directly, or indirectly through one or more intermediaries, controls or is controlled by, or is under common control with, the specified entity.
Please read the following to understand how Personal Data collected on our websites may be used and shared. This Privacy Policy discloses our information gathering and dissemination practices for our main website http://freshenopt.ca and all other FreshenOPT Group websites linked thereto and/or owned by FreshenOPT Inc. ("Sites").
II. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is current as of the effective date set forth above. FreshenOPT reserves the right to change this Privacy Policy from time to time consistent with applicable privacy laws and principles. Unless such changes afford greater protections, such changes will apply only to Personal Data received after the effective date of such change. If at any time you choose not to accept the terms of this Privacy Policy, you should not use our Sites.
III. PERSONAL DATA COLLECTION AND USE
Services and transactions. We use your personal information to deliver services or carry out transactions you have requested, such as providing information on FreshenOPT products, registering purchased products, processing product orders, handling warranty claims, replacing product manuals, answering customer service requests, facilitating use of our websites, and so forth. In order to offer you a more consistent experience in your interactions with FreshenOPT information collected by our websites may be combined with information we collect by other means.
Lawful and correct treatment of Personal Data is very important to us. If you sign up to receive additional information about any of our products or services, request our e-mail newsletter, or wish to use other special features or services offered through our Sites, you may be asked to provide Personal Data about yourself.
For purposes of this policy, "Personal Data" means data that personally identifies an individual or that may be used to personally identify an individual. This includes, but is not limited to data such as an individual’s name, date of birth, phone number, address and e-mail. Personal Data does not include data that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Data. If you decide not to provide us with Personal Data, you will still be able to use certain parts of our websites, although there may be some features or services that are unavailable to you. Unless otherwise noted below, FreshenOPT will not use or disclose your Personal Data for any purpose for which you have not consented. Please note that consent will be inferred if you were made aware of all potential subsequent uses of your Personal Data at the time it was collected. By submitting Personal Data on our Sites, you allow us to use such information for its intended purpose.
If you provide your Personal Data to receive information about any of our products or services, you may opt out of receiving such information at any time by following the opt-out link provided in any of the e-mails you receive from us.
The information FreshenOPT collects is primarily used to provide information about our services and products to our customers and business partners. FreshenOPT will not rent or resell your Personal Data to third parties for marketing purposes.
In particular, FreshenOPT may collect and/or process the following information about you:
Information that you provide by filling in forms on our Sites, such as your name, address, e-mail address, phone number, the types of products you are interested in and information about your occupation. This includes information you may provide when you request additional information about our products and services or sign up to receive one of our e-mail newsletters.
Your contact information when you report a problem with one of our Sites.
Details of your participation in any market research we may conduct on our website, such as when you provide feedback about our products online.
If you contact us, we may keep a record of that correspondence.
If you enter a contest or promotion sponsored by us or any of our group companies, FreshenOPT may ask you for your contact information as well as other information about you to verify your eligibility to participate and to award prizes. Please note that participating in such contests is completely voluntary and is not required to use our Sites.
FreshenOPT may ask you to complete surveys that request certain demographic information (such as your age, income, occupation and postal code) and/or additional information about yourself which FreshenOPT may use for research purposes. Please note that you do not have to respond to these survey requests.
IV. NON-PERSONAL DATA
In some cases, FreshenOPT may collect information that is not personally identifiable. Examples of this information includes, but is not limited to, the frequency of your use of our Sites and the route by which you choose to access it and your use of any hyperlinks available on any of our Sites. We and our service providers, agents or suppliers may process and use this data for purposes including, but not limited to, website development, assessing patterns of use, or planning and assessing FreshenOPT marketing initiatives. This information is gathered by certain tools and methods such as the collection of your IP address or the use of cookies and is maintained in the aggregate unless otherwise noted. To the extent that we link any non-Personal data with Personal Data, we will treat such linked information as Personal Data. We reserve the right to add or test additional future tracking technology to improve or personalize the user experience and gain insights into the needs and shopping habits of our visitors as it relates to our products.
Cookies
In order to improve our site, we utilize "cookies" to maintain a record of your visit, by using a cookie file that is stored on the hard drive of your computer. A cookie is a small text file that is transferred to a web browser by a web server and can only be read by the server that gave it to you. This information does not identify you personally and you remain anonymous unless you have otherwise provided us with Personal Data.
Cookies help us to improve our site and to deliver more personalized service by enabling us to estimate audience size and usage pattern; to store information about your preferences; to speed up your searches and may be used to recognize your computer.
Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your Internet browser's steps for doing so. Please note, however, that if you do disable cookies from your browser, you may not be able to access certain sections of our websites.
IP Addresses
We use your IP address to help diagnose problems with our server, and to administer our Sites. We may also use your IP address to identify you when we feel it is necessary to enforce compliance with this Privacy Policy or our website Terms and Conditions, or to protect our services, Sites, systems, information, employees, business partners, service providers, users, customers or others.
Pixels
Third parties with whom we contract may place and use pixels on our websites which are associated with cookies to allow internet-based ads to FreshenOPT website visitors who visit other websites.
Google Analytics
Our sites may use Google Analytics to track demographics and interests of our visitors, but is not personally-identifiable. Tracked information may include: age, gender, and interests based on browsing history. We will use this information for marketing purposes. Users can opt-out of being tracked here: https://tools.google.com/dlpage/gaoptout/
V. DISCLOSURES/ONWARD TRANSFER
FreshenOPT may disclose your Personal Data to any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiaries in compliance with applicable privacy principles, regulations and rules.
In order to more efficiently provide the products and services you may request from us, FreshenOPT may also share your Personal Data with selected third parties who are acting or gathering information on our behalf as our agents, suppliers, or providers.
To this effect, we may disclose Personal Data to the following:
Third parties who perform tasks on our behalf; and
Third parties who agree to provide adequate protections for your Personal Data that are no less protective than those set out in this Privacy Policy; and to use your information only for the purposes for which the third party has been engaged by us.
We may also disclose your Personal Data to third parties if:
We sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such businesses or assets.
Any member of our group or substantially all of its or their assets are acquired by a third party, in which case Personal Data held by it about its customers will likely be one of the transferred assets.
We are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, subpoena or other court order; or in order to enforce or apply any of our online Terms and Conditions and other agreements; or to protect the rights, property or safety of our group companies and organizations for the purposes of fraud protection and credit risk reduction; or for any other reason as required or permitted by law.
VI. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
If you have submitted Personal Data through a FreshenOPT Group Site and you would like to review, request changes or have that information deleted from our databases, please contact FreshenOPT via email at support@freshenopt.ca, or send a letter to FreshenOPT Inc. at FreshenOPT, UNIT 14-85 FERRIER STREET, MARKHAM, ONTARIO, L3R2Y9. Attention: Legal Department.
We will use all reasonable efforts to supply you with a copy of your Personal Data and/or correct any factual inaccuracies. Upon request, we will remove such information from our databases unless we are entitled or required to retain it pursuant to other agreements or by law.
Be sure to include your name and clear instructions regarding any change or deletion. In the event you choose to delete your Personal Data from our database, we will retain a record that such information had been deleted as well as your request for deletion as evidence of our compliance with this Privacy Policy.
VII. SECURITY AND DATA INTEGRITY
We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee its security and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
VIII. OTHER SITES
Our Sites may contain links to other websites, including the websites of third parties who are acting on our behalf as our distributors, suppliers, or providers.
FreshenOPT is not responsible for the content, security, or privacy practices employed by third party websites. Once you leave our website, we encourage you to review the privacy policy of any website linked to from one of our Sites before using it.
IX. OPT-OUT
If you no longer wish to receive information concerning our services or products, please contact us at the e-mail address listed below to notify us of your wishes.
X. COMPLAINTS
FreshenOPT takes your privacy concerns seriously. If you believe that FreshenOPT has not complied with this Privacy Policy with respect to your Personal Data, you may write to support@freshenopt.ca, or send a letter to FreshenOPT at FreshenOPT, UNIT 14-85 FERRIER STREET, MARKAHM, ONTARIO, L3R2Y9. Attention: Legal Department.
XI. Messaging Privacy Policy
This Messaging Program Privacy Policy explains how FreshenOPT Inc. collects and uses information about you in relation to its text message marketing program (the "Messaging Service"). We use Klaviyo through an integration to provide the Messaging Service to you. For the purposes of the Messaging Service, Klaviyo acts as our service provider and data processor of your information.
1. Collection of Information
We collect various information on our behalf from and about you, including information you directly provide when you use the Messaging Service. For example, we collect the phone number and email address you provided when signing up for the Messaging Service. When you send messages via the Messaging Service, we will also collect your messaging history and any information included in those messages.
We may also collect information about you using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your device. Cookies enable personalization of your experience on the Messaging Service (e.g., sending you personalized text messages such as shopping cart reminders).
If you participate in a contest, sweepstakes, research study, or email survey associated with the Messaging Service, we will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your contact information if you contact us with questions about the Messaging Service or for customer service.
2. Use of Information
We use your information to deliver, analyze, maintain and support the Messaging Service. We may also use your information to enhance the Messaging Service features and customize and personalize your experiences on the Messaging Service.
3. Sharing of Information
We may share, transfer, or disclose your information, if you consent to us doing so, as well as in the following circumstances:
Service Providers. Service Providers. We may share your information with third parties to help us provide the Messaging Service to you.
Legal Requirement and Protection of FreshenOPT Inc. and Others. We may disclose your information as we believe such disclosure is necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce a contract with us; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.
From time to time, we may share aggregate or de-identified information about use of the Messaging Service and such aggregated or de-identified information may be shared with any third party, including advertisers, promotional partners, and sponsors.
3. Protection of Information
We take a variety of physical, technical, administrative, and organizational security measures based on the sensitivity of the information we collect to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. Unfortunately, no online activity can be guaranteed to be 100% secure. While we strive to protect your information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide. We do not accept liability for unintentional disclosure.
4. Retention of Information
We retain your information for as long as you participate in the Messaging Service or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect us and our customers, and enforce our agreements.
5. Choices and Controls
Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. For additional opt-out information, please review our Terms.
6. Customer Care
If you are experiencing any problems with the Messaging Service, please email support@freshenopt.ca.
7. Main Privacy Policy
By signing up to receive text messages from us, you also agree to our main Privacy Policy.
