ESOPH™ ‘ COMMITMENT TO PRIVACY
EsopH™ (“EsopH” or “we” or “us”) with its natural vitamins, minerals, concentrated food supplements, herbs and botanical medicines, is a leader in the research, development, manufacturing, distribution and marketing of a broad range of natural health care products.
Personal information is any information about an identifiable individual, such as Your name, email address, mailing addresses, gender, date of birth, any answers and data You elect to provide to questionnaires, information collected electronically through EsopH™ ‘ web site located at www.Esoph.ca or other web site(s) operated by EsopH™ time to time (each a “EsopH™ site”), and any other information that identifies who You are. Personal information about You may be collected by EsopH™ directly or provided to EsopH™ by third parties.
WHAT PERSONAL INFORMATION DOES ESOPH™ COLLECT?
EsopH™ limits the collection and use of Your information to that which is necessary to fulfill identified purposes or to deliver requested information, products or services to You. If we intend to use Your information in any way we didn’t tell You about previously, we will obtain Your consent for the new purpose or use prior to doing so.
The information we ask for will depend on the information or service requested. Different information and services require different types of information. Your information may be collected via an “active information collection point” or through passive means.
- ACTIVE INFORMATION COLLECTION
You might choose to actively provide EsopH™ certain kinds of personally identifiable information, such as Your full name, address, phone number, e-mail address and other personal details, including by submitting or posting same to a EsopH™ site. All information that You actively provide to EsopH™ is provided at Your option.
There are many ways You can give Your consent to our use of information that You provide.
Your express consent may be given in writing, verbally or through electronic means. Alternatively, where permitted by law, Your consent may be implied through an action You’ve taken or when You continue to use a product or service after we’ve notified You of a change. For certain communications and services, we will verify Your express consent prior to commencing the requested service or communication.
EXAMPLES OF EXPRESS CONSENT:
Written – Signing a form that states “I agree to the terms.”
Electronic – Clicking on an “I agree” or “I accept” or similar button online.
Verbal – Responding to a direct question from a EsopH™ representative via telephone communications.
EXAMPLE OF IMPLIED CONSENT:
Action You’ve taken – There are many potential examples where You may provide information to EsopH™ for a particular purpose and Your consent for EsopH™ to use the supplied information is implied for the purpose for which it was supplied:
- completing a registration form in order to access and use a particular feature or function on a EsopH™ site
- submitting questions or comments to EsopH™
- submitting feedback about EsopH™ or products and services and other topics
- requesting information about EsopH™, EsopH™ products and related information
- completing surveys and evaluations
- participating in promotions or contests
- PASSIVE INFORMATION COLLECTION
EsopH™ sites may use various technologies to passively collect information from You while You are visiting (that is, You do not actively provide this information to EsopH™). Such technologies allow the EsopH™ Site to collect a range of non-personally identifiable information, including Your Internet Protocol (IP) address (a unique identifier automatically assigned to Your computer when logging onto the Internet), the type of Web browser and operating system You use, the date and time You visit the EsopH™ Site, the specific pages You visit on the EsopH™ Site, and the address of the Web site You visited before coming to the EsopH™ Site.
EsopH™ typically uses such passively collected information for a variety of purposes, such as to administer the EsopH™ Site, customize the EsopH™ Site to Your preferences, and compile aggregated statistics for marketing and research purposes. EsopH™ reserves the unrestricted right to use this passively collected, non-personally identifiable information, including, but not limited to, selling, leasing, permitting access to, or otherwise transferring it to our affiliates, business partners, advertisers and other third parties.
The “passive information collection” technologies that we use may include “cookies”. Cookies are small text files that store information about Your interactions with a particular Web site, either temporarily (known as a “temporary” or “session” cookie, and deleted once You close Your browser window) or more permanently on the hard drive of Your computer (known as a “permanent” or “persistent cookie”). Cookies can make it easier to use a Web site by allowing servers to access certain information quickly:
“Session” cookies can be used to help a user’s browser navigate a Web site more smoothly and may show up if the user comes from a Web site with which the subsequent Web site has some relationship (e.g., a Web site of an affiliated company) and can give helpful information. “Persistent” cookies can be used to customize a Web site for a user, such as by storing passwords, preferences, and registration and account information so that users do not have to re-enter them each time they visit a Web site.
USES AND DISCLOSURE OF INFORMATION
Except as described in this Policy or as You may otherwise consent to from time to time, EsopH™ will not use, and will not disclose or provide any of Your personal information to any other person. We do not sell, trade, or rent Your personal information to others for marketing purposes. As described above, generally, the purpose for collecting Your personal information will be explained to You, in clear language, at the time of collection.
When You provide information to EsopH™ by completing a registration form, submitting questions or comments or feedback concerning EsopH™ or products and services and other topics, completing surveys and evaluations and other similar situations, we will use this information to learn more about our customers and their preferences, improve our products, services and the EsopH™ Sites and for related marketing and research purposes.
EsopH™ reserves the right to transfer any information submitted by You and retained by EsopH™ to EsopH™ affiliates to the extent necessary to perform requested services and provide requested information. EsopH™ may sell all or part of its business, sell or securitize assets, or merge or amalgamate part or all of our business with other entities. Since customer information and data would normally be a part of such transactions, we may use or disclose such information to other parties included in the transaction, as part of due diligence activities and/or on the completion of the transaction.
EsopH™ does not knowingly collect personal information from children under the age of 18.
EXCEPTIONS WHERE ESOPH™ MAY COLLECT, USE OR DISCLOSE INFORMATION WITHOUT CONSENT
If we are required or permitted by law: We may be required to release information by a court of law or other legal or regulatory authority. If so, our policy is to release information only to the extent that we have to. We may also collect, use or disclose information without consent where permitted by law. For example, we may collect and use publicly available information like information in the telephone book for marketing or customer service purposes. Further, for other legal, medical, emergency or other security reasons, it may be impossible or impractical to seek or obtain Your consent.
If we use an outside third party supplier to do work for us: We may from time to time use outside third party suppliers to do work for us involving some of Your information. For example, to perform computer services on our behalf or to analyze survey results or marketing data or to administer to manage promotions or contests or for other reasonable purposes. We select the company carefully and confirm that it uses privacy and security standards that meet EsopH™’s requirements. If such third parties are located outside of Canada EsopH™ will notify You prior to any such transfer taking place.
If we have to protect the interests of EsopH™: In certain circumstances, EsopH™ may have to collect, use or release information without consent for its protection. For example, we may do so to detect, investigate or prevent fraud.
RIGHTS TO PROVIDE INFORMATION
With respect to all content and information You submit to EsopH™, including by submitting or posting to the EsopH™ Site, in providing us with such content and information we rely on You to ensure that You have the lawful right to do so without limitation or restriction.
EsopH™ may collect aggregated, anonymous information (such as demographic and profile data, usage and selection data and similar information and data) about You, including in connection with Your use of a EsopH™ Site, Your participation in various EsopH™ promotions or contests and otherwise in connection with the purchase of EsopH™ products and use share that information with other third parties (such as EsopH™ ‘ service providers, agents, marketing consultants and advertisers) in order to better understand and learn more about our customers and their preferences, improve our products, services and the EsopH™ Sites and for related marketing and research purposes. Any such aggregated information will not contain personally identifiable information about You.
EsopH™ will keep Your information only for as long as it is reasonably needed to fulfill the purposes for which it was collected, unless and to the extent a longer retention is permitted or required by law. Your information is destroyed when it is no longer needed or it is converted to an aggregated and anonymous form. The length of time we keep Your information varies depending on the reason it was collected and the nature of the personal information. For legal reasons, we may keep information beyond the end of Your relationship with us.
ACCURACY & ACCESS TO YOUR INFORMATION
You have the right to access, verify, rectify and update Your personal information. EsopH™ takes reasonable steps to ensure Your personal information is accurate, complete, and up-to-date. However, in certain circumstances, we must rely upon You to advise us if Your personal information changes. If You notify us that Your personal information is inaccurate or incomplete, we will take steps to correct, delete, or add to it, as appropriate.
You can contact EsopH™ to request to know what information EsopH™ may have collected and retained about You and how that information is being used. Depending on the nature of the information You are requesting and complexity of Your request, we may ask You to put Your request in writing. In some instances on, You may be able to log into Your account profile or preferences on a EsopH™ Site to view and/or modify Your information, as appropriate.
We protect other people’s privacy when we make information about You available to You. It may not be appropriate for us to release certain information directly to You. There may be records that include information about You and other customers, or that have information confidential to EsopH™ or are the property of EsopH™. Because we must protect everyone’s confidentiality and legal rights, we cannot make these records available to persons outside of EsopH™. We will, however, make available to You any factual information about You contained in such records. If we are unable to disclose information to You, we’ll explain why, subject to any legal restrictions. If You wish to challenge our decision, we will tell You how to escalate Your request.
YOU CAN WITHDRAW YOUR CONSENT
Subject to legal and contractual requirements, You may change or withdraw Your consent at any time (which includes electing not to receive further communications or other services from us) by: (1) changing Your choice on the EsopH™ Site, if and where available; (2) using the unsubscribe feature, in the case of e-mail distributions if and where available; or (3) contacting EsopH™ ‘ Director of Communications in the “Contacting EsopH™ ” section of this Policy below.
Withdrawing Your consent will generally not affect Your relationship with EsopH™ or eligibility to receive EsopH™ offers. However, if You don’t consent or if You withdraw Your consent, we may not be able to provide You with a particular service or provide You with requested information. When You change or withdraw Your consent, we will do our best to make sure that our files are updated as quickly as possible. It may take some time for our records to reflect Your changes as many records can only be changed during regular file updates.
SAFEGUARDS AND SECURITY
We will use reasonable efforts to protect information that You provide to EsopH™ once it has been received by EsopH™. EsopH™ employs physical, administrative and technical safeguards, reasonably appropriate to the sensitivity of the information, to safeguard Your personal information against loss, theft, misuse, unauthorized access or disclosure and alteration.
For example, with respect to EsopH™ Sites, EsopH™ uses SSL (Secure Socket Layer) technology, an encryption technology used to encrypt information sent from Your computer to our servers over the Internet. Unfortunately, no data transmission over the Internet or system can be guaranteed to be 100% secure.
Although EsopH™ uses reasonable efforts to safeguard Your information, we cannot guarantee it. EsopH™ cannot ensure or guarantee that any information You provide to EsopH™ is completely secure from individuals who might attempt to deliberately evade security measures, including by intercepting transmissions over the Internet. You provide EsopH™ with Your information at Your own risk.
CONFIDENTIALITY OF SUPPLIED INFORMATION
In order to protect the security and confidentiality of any personally identifiable information supplied by You to EsopH™ (such as web site passwords and similar information relating to or concerning You) You are responsible to ensure all such information is kept confidential and secure by You.
EsopH™ ‘ Director of Marketing is the individual responsible for this Policy and EsopH™ ‘ compliance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act.
If You have any questions, comments or complaints about this Policy or our handling of Your personal information, or if You wish to withdraw Your consent to our use of Your personal information (subject to reasonable notice, any legal requirements and similar exceptions) or to request access to or update any information we have on file, you may contact our Director of Marketing using the contact information below:
By Telephone: 905-475-1234
By Email: email@example.com
My Letter: 100 Spy Court, Markham, ON L3R 5H6
EsopH™ will use reasonable efforts to promptly respond to all questions, inquiries and complaints received, and will typically respond to You within 30 days. Except where required by law, EsopH™ cannot ensure a response to questions or comments regarding topics unrelated to this Policy or EsopH™ privacy practices. If any question, inquiry or complaint is not resolved to your satisfaction, You may contact:
Office of the Federal Privacy Commissioner
112 Kent Street Ottawa, Ontario K1A 1H3
Toll Free: 1-800-282-1376
REVISIONS TO POLICY
EsopH™ reserves the right to modify this Policy at any time. If amended, EsopH™ will post an amended Policy on the Policy page of each applicable EsopH™ site. You may contact EsopH™ as described in this Policy to obtain a copy of the Policy at any time.