HEAL
WELLNESS INC.
USER PRIVACY POLICY
This
privacy policy (this “
”)
describes the practices of HEAL Wellness Inc. and its corporate affiliates (“
”) with respect
to our collection, use, storage and disclosure of personal information provided
to us from users of (a) the website operated at healthyeatingandliving.ca,
healwellnesschallenge.com, and such other locations as made available from time
to time (the “
”), (b) any
“app” or other front-end software provided by us (for greater certainty,
excluding third party software that may interact with the Website or the
Service, as defined below) that interacts or interfaces with the Website (the “
”), (c) coaching, meal plan,
and Corporate Wellness services, made available through the Website and/or the
Software, and (d) our webinars and article comment fields, made available through the Website and/or the
Software (collectively, the “
”). It also describes the choices available to
you regarding our use of your personal information and how you can access and
update this information. This Policy is
incorporated by reference to the General Terms of Use located at [www.healthyeatingandliving.ca/terms-of-service],
and forms an integral part of it.
1.
Introduction and General Concepts
We
respect and uphold individual rights to privacy and the protection of personal
information. We know how important it is to protect your personal information
and want to make every customer experience safe and secure. In keeping with
that goal, we have developed this Policy to explain our practices for the
collection, use, and disclosure of your personal information. We have appointed
a Privacy Officer who is responsible for our compliance with this Policy. Information
on how to contact the Privacy Officer can be found below.
(a)
Personal
Information
For
the purposes of this Policy, “
” 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 (“
(b)
Non-Personal
Information
On
the other hand, “
” 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 Website, or the type and version of device, browser or
operating system being used to access the Service), or aggregate information
that anonymizes the underlying data (like the number of visitors, what pages
users visit, average time spent on the Website or on various parts of the
Service). 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.
(c)
Information
about Minors
We
encourage parents and guardians to spend time with their children online, and
to be fully familiar with the sites visited by them. However, our site is not
intended for minors. We do not knowingly collect or use personal information
about any person under the age of majority (usually the age of 18 or 19, but it
varies in different jurisdictions), and no such person, nor any parent or
guardian as it relates to such person, should submit their personal information
to us for any reason. Further, pursuant to Children’s Online Privacy Protection
legislation, we do not use or collect information of individuals under the age
of 13. Please do not submit personal information about minors to us, whether
through the Website, the Service or otherwise. We require that persons under
the age of majority in their legal jurisdiction instead have a parent or
guardian do so on his or her behalf, and only use this service through such
parent or guardian
(d)
Privacy
Officer
We
have appointed a Privacy Officer who is responsible for our compliance with
this Policy. Information on how to contact the Privacy Officer can be found
below.
2.
Collection and Use of Personal Information
As
indicated above, we collect two types of information through our Service: 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 Service.
(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;
·
billing
information such as credit card number, and billing address;
·
unique
identifiers such as user name, account number, password;
·
user content
generated by you, such as audio, video, text and images as provided by you on
the Website, which may contain personal information as provided by you;
·
any
information that you voluntarily enter, including personal information into any
postings, comments, reviews, or forums; and
·
preferences
such as order history, purchase preferences, marketing preferences, and step count or movement data collected through our wellness app
(b)
Information
we automatically collect
We
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:
·
—When using
our Website, we may collect the Internet Protocol (IP) address of your
computer, the IP address of your Internet Service Provider, the date and time
you access our Website, the Internet address of the website from which you
linked directly to our Website, the operating system you are using, the
sections of our Website you visit, the Website pages read and images viewed,
and the content you download from the Website.
This information is used for Website and system administration purposes,
and to improve the Website.
·
—We use “cookies”, a technology that installs
a small amount of information on a user’s computer to permit the Website to
recognize future visits using that computer. Cookies enhance the convenience and
use of the Website. For example, the information provided through cookies is
used to recognize you as a previous user of the Website, to offer personalized
content and information for your use, to track your activity at the Website, to
respond to your needs, and to otherwise facilitate your Website experience. You
may choose to decline cookies if your browser permits, but doing so may affect
your use of the Website and your ability to access certain features of the
Website or engage in transactions through the Website.
·
—When you
use the Service through a mobile device, we may track or collect your
geo-location information on a real time basis only. We may also use this
real-time geo-location information to address support, technical, or business
issues that may arise in the course of your use of the Service. If you do not consent to the tracking of your
geo-location, you may still be able to use some features of the Service, but it
is intended to be used with geo-location information. For example, your
location may be used on a mobile application to locate the closest health food
stores for your convenience and access
You may at any time withdraw your
consent as permitted through the Service, or you can turn the geo-location
tracking off at the device level as permitted by the manufacturer of your
device. In our experience, your mobile device informs you when geo-location is
tracked by displaying the GPS arrow icon.
3.
Use of Personal Information
We may use
your personal information, in combination with your non-personal information,
for a variety of business purposes, for example to:
·
fulfill your
order or enable a third party to fulfill your order;
·
send you an
order or appointment confirmation;
·
send you
requested product or service information;
.
allow you
to participate in our wel;ness challenge program;
·
send new
product or service information;
·
respond to
customer service requests;
·
administer
your account;
·
to contact
you when you have emailed us about the Wellness Challenge;
·
send you a
newsletter;
·
carry out
contests or promotions;
·
send you
marketing communications;
·
respond to
your questions and concerns;
·
improve our
Services and marketing efforts;
·
conduct
research and analysis;
·
enforce out
Terms of Use;
·
distribute
to our payment processor for the provision of payment services;
·
facilitate
your transactions with other users, as applicable;
·
display
content based upon your interests;
·
facilitate
your transactions with other users; and
·
execute
other purposes as described in this Policy.
4.
Your Consent
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.
(a)
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.
(b)
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
forms while placing an order, you provide us with implied consent to use that
address in order to fulfill your order.
(c)
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 Service, or (ii) deleting your account with the Service and
stopping use of the Service. 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 info@healthyeatingandliving.ca.
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 Service, or information
that you requested. For example, we require your email address in order to
verify your account, which is necessary so that newsletters or requests for
additional information to ship you a purchase may be sent to you
electronically.
5.
Information Obtained from Third Parties
If
you provide us personal information about others, or if others give us your
information, we will only use that information for the specific reason for
which it was provided to us and in accordance with this Policy and such policy
under which that information was collected. For example, we may collect general
information from your employer, such as the number of participants expected to
attend a Corporate Wellness seminar.
6.
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 Service necessarily requires some sharing
or disclosure of your personal information.
Some of these activities may result in personal information collected by
us being stored or processed in the United States or elsewhere outside of
Canada and, as a result, your personal information may be accessible to law
enforcement and regulatory authorities in accordance with the USA PATRIOT Act
and other applicable laws of the United States or elsewhere.
(a)
Third Party
Processors
We
may provide your personal information to companies that provide services to
help us with the Service such as web hosting providers, payment processors, testing
centers, booking providers, product shipping providers, fulfilment agencies, or
customer service agencies (“
”). 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 we believe will only use your information in compliance with this Policy,
but they may have their own specific policies regarding the collection, use and
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. For
example, we may use the services of a third party payment processor for placing
your order (even if the payment processing is “transparent” or embedded so it
appears as though you are on our Website or application). We strongly suggest
that you check with the applicable third party payment processor to see if and
what privacy terms apply to your use of these services.
Here are some examples of the Third Party
Processors we use as part of the Service:
·
The services
for our Service is hosted by [Stripe],
a reputable hosting platform with industry standard security and
practices.
·
We do not
directly process payments through our Service. We use [Stripe] as a payment processor and their
privacy terms are available here:
.
We only ourselves collect and store limited parts of that information to
provide a record of your transaction and to prevent (such as a part of a credit
card number, or a part of your billing address).
·
We do not
provide the Hormone, Allergy, or similar services offered through our
Services. Rather, we link to a Third
Party Processor, which provides a way to purchase the Third Party Processor’s
test through Shopify as an e-commerce platform. We will provide your address
that you input for shipment to this Third Party Provider, which will send a
test kit to you, where you can follow the instructions provided in the test
sent by this Third Party Processor. Once you have received the results, we will
then meet to discuss the results you choose to share with us.
·
When you enter
information into any “comments” field through the Service, we forward certain
aspects of the information you provide to [Stero Chrom lab or ZRT Labs, for testing services of any
additional services where the End user provides information that goes to a
third party to run a test/provide a response] to enable them to assist
in performing parts of the Service. We have entered into contractual
arrangements with these parties to ensure that they abide by this Policy.
·
We use a
third party to gather information about how you and others use our Service. For
example, we will know how many users access a specific page and which links
they clicked on. We use this aggregated information to understand and optimize
how our site is used. We may also use
unique codes, web beacons or single-pixel gif tags to compile tracking
information reports regarding Service user demographics, Service traffic
patterns, and other aggregated Website or Service statistics, both on the
Website and in our electronic communications in order to determine which
materials 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, and is used to represent a separate user their use of the
Service, as opposed to identifying that particular user.
·
You can log
in to our Service using sign-in services such as Facebook Connect. These
services will authenticate your identity and provide you the option to share
certain personal information with us such as your name and email address to
pre-populate our sign up form. Services like Facebook Connect give you the
option to post information about your activities on this Service to your
profile page to share with others within your network.
·
We make your
contact information available to other users that you transact with on this
site to help complete the transaction, in accordance with your selected
preferences.
(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
Service 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.
(d)
Public
Forums
We
may from time to time provide through the Service publicly accessible blogs or
community forums. We will use your
personal data as provided through those services to administrate and provide
you with these public services, and you will have primary control over what
information you make publicly available. You should be aware that any
information you provide in these areas may be read, collected, and used by
others who access them.
7.
Security of Personal Information
(a)
General
Security Practices
The
security of your personal information is important to us. We follow generally
accepted industry standards to protect the personal information submitted to
us, both during transmission and once we receive it. We employ physical,
administrative, contractual and technological safeguards to protect personal
information, and insist that our service providers do the same. We insist that our personnel, and those of
our providers, only access and use personal information in order to properly
perform those duties, and even then only to the strict extent necessary to
perform them.
(b)
Online
Security
We
do not accept information that requires encrypted security as payment
processing is provided by our third party providers. We believe that these
third party providers that we believe encrypt the transmission of that
information using secure socket layer technology (SSL); however such terms
shall be provided in the applicable terms and conditions of the third party
processors, which you are advised to review on their sites. No method of
transmission over the Internet, or method of electronic storage, is 100%
secure, so you should always exercise caution when disclosing sensitive
information over the Internet.
If
you have any questions about security on our Website, you can contact us at info@healthyeatingandliving.ca.
8.
Requests for Access to and Correction of
Personal Information
Applicable
Privacy Laws allow, to varying degrees, individuals 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 it 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.
9.
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.
10.
Updates or Changes to Privacy Policy
We
may update this Policy to reflect changes to our information practices. If we
make any material changes we will either (a) notify you by email (sent to the
e-mail address specified in your account), or (b) provide a notice on the
Website or otherwise through the Service prior to the change becoming
effective. We encourage you to periodically review this page for the latest
information on our privacy practices. Any change to this Privacy Policy will
become effective on the date so indicated, and will apply to information
collected from the date of the posting of the revised privacy policy and to
existing information held by us. The
date on which the latest update was made is indicated at the bottom of this
document. We recommend that you print a
copy of this privacy policy for your reference and revisit this policy from
time to time to ensure you are aware of any changes. Your continued use of the Service signifies
your acceptance of any changes to this Policy.
11.
Contact Information
You can
direct any questions or concerns regarding our compliance with this Policy to
our Privacy Officer by writing or emailing at:
Privacy
Officer
HEAL Wellness Inc.
139 Osborne Road West, North Vancouver, BC, V7N 2P9 Email: info@healthyeatingandliving.ca
If
you are not satisfied with our Privacy Officer’s response to their question or
concern you may be able to make a complaint under Applicable Privacy Laws. Our Privacy Officer can provide you with the
contact information to make such a complaint.
End of Privacy Policy (Last Updated: February 18, 2025).
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