At Sun-Rype Products Ltd. ("Sun-Rype"), we are committed to protecting the privacy of our consumers, customers, employees, shareholders and other individuals served by or providing services to Sun-Rype. The proper safeguarding of all personal information collected in the course of Sun-Rype's day-to-day activities is the cornerstone of this commitment.
The purpose of this Privacy Policy is to inform you of Sun-Rype's practices relating to our collection, use, disclosure and protection of your personal information. Our Privacy Policy explains how you can contact us if you have a question about, want to make a change to, or delete, any personal information that Sun-Rype may retain about you.
Sun-Rype's Privacy Policy is designed to meet the compliance standards embodied in applicable privacy legislation to ensure that all information is properly collected, used only for the purpose for which it was collected, and disposed of in a safe and timely manner when it is no longer needed. These compliance standards are based on the Ten Principles established by the Canadian Standards Associations Model Code for the Protection of Personal Information, which principles were recognized as a Canadian standard in 1996, and address the ways in which organizations should collect, use and disclose personal information.
Definition of Personal Information
"Personal information" means any information about an identifiable individual, other than that individual's name, title, business address or telephone number (often called, "business card" or "phone book" information). Personal information includes age, gender, marital status, health status, financial status, home address or telephone number, etc.
Our Ten Privacy Principles
- Accountability
Sun-Rype is responsible for maintaining and protecting the personal information under its control. Sun-Rype has appointed a Chief Privacy Officer who is responsible for ensuring Sun-Rype's compliance with its privacy obligations.
- Identifying Purposes
What Personal Information Do We Collect?
The information we collect, which may include personal information, may involve at least some of the following:
- Contact information (such as name, postal address, email address, telephone or fax numbers, etc.); and
- Survey-type information (such as consumer product preferences, age, marital and family status, financial status, gender, etc.).
How Do We Use Personal Information?
Sun-Rype may use this personal information to communicate with our consumers, customers, shareholders, and other individuals to share company information with them and to advise them of new products, contests and/or promotions.
Sun-Rype also collects personal information from our employees for the purposes of establishing, maintaining or terminating the employment relationship including managing payroll, benefits, employee performance evaluations, making recruitment and selection decisions, and to meet legal, security or regulatory requirements.
Sun-Rype will identify the purposes for which we are collecting personal information before information is collected.
If Sun-Rype wishes to use personal information for a purpose not contemplated at the time of collection, your consent will be sought in advance.
- Knowledge and Consent
Information Voluntarily Provided
Sun-Rype collects personal information about an individual only when it is voluntarily provided. Individuals will be informed and their consent obtained for the collection, use and disclosure of their personal information, except where otherwise required or permitted by law. When it is appropriate, the written consent of the individual will be obtained (i.e. by mail, email or fax). Sometimes, an individual's consent may be obtained verbally or implied through their conduct with Sun-Rype.
As well, Sun-Rype may periodically request written confirmation from an individual that the information collected and maintained by Sun-Rype is up to date and accurate. Sun-Rype, at our option, may also ensure that we have continuing consent to use and retain personal information.
Sun-Rype will disclose personal information, without notice and without consent, only if required to do so by law or in the good faith belief that such action is necessary to:
- cooperate with regulatory bodies and law enforcement officials to conform to obligations imposed by law or statute;
- meet an emergency need; or
- as required pursuant to an investigation.
Cookies
When you visit our web site, www.sunrype.com, please note that cookies may be used on some pages of our site. "Cookies" are small text files placed on the visitor's hard drive that assists us in providing a more customized web site experience. Cookies cannot be used to obtain personal information about you or to access information on your computer. However, they do allow our web site to designate certain attributes to certain users and use this information to track a user's activities on our web site. For example, our web site may use cookies for various activities, including contests, games and tracking visits to our web pages. If you are concerned about cookies, most browsers permit you to decline cookies. However, some of the features on Sun-Rype's web site may require that the cookie function in your browser be enabled in order for the feature to be fully functional.
Links to Third Party Web Sites
There are several places throughout www.sunrype.com that may link to other web sites that do not operate under Sun-Rype's Privacy Policy. When you link to other web sites, Sun-Rype's Privacy Policy no longer applies. We encourage you to review each site's Privacy Policy before disclosing any personally identifiable information.
Our Commitment to Children
Sun-Rype is committed to protecting the privacy of children. No information should be submitted to or posted on our web site by children under the age of majority without their parent's or guardian's permission. In addition, if a user younger than the age of majority wishes to send us personal information, he or she must first obtain his or her parent's or guardian's email address to that we can obtain their permission.
- Limiting Collection
Sun-Rype only collects the personal information that is required to meet the purposes identified by Sun-Rype. Sun-Rype is committed to collecting personal information in a fair, open and lawful manner. For this reason, Sun-Rype does not indiscriminately collect personal information.
- Limiting Use, Disclosure and Retention
Sun-Rype does not use personal information for purposes other than those for which it was originally collected, unless it has first obtained the consent of the person from whom such information was received. Sun-Rype retains personal information only for as long as it is needed and only for the fulfillment of the purposes for which it was originally collected.
- Accuracy
Personal information is maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purpose for which it was collected.
- Safeguards
Personal information is protected by security safeguards appropriate to the sensitivity of the personal information. Sun-Rype's security safeguards include:
- premises security;
- locked file cabinets;
- restricted access to files containing personal information;
- technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
- internal passwords and security policies to control access to the Sun-Rype network and software; and
- policy prohibitions against unauthorized use or disclosure.
If Sun-Rype uses the services of any third parties to process personal information, Sun-Rype will enter into legal agreements that require them to protect this personal information in a manner acceptable to Sun-Rype. In entering into these legal agreements, Sun-Rype does not transfer any interest in this personal information to them. Rather, the purpose of these legal agreements is to ensure that the personal information delivered to third parties is maintained at a level of security equal to that provided by Sun-Rype under this Privacy Policy.
Sun-Rype also ensures that any of its employees who deal with personal information are properly trained and are aware of the necessary and appropriate measures required to protect personal information.
- Openness
Sun-Rype will make available to individuals on whom it may keep records, all relevant information about Sun-Rype's policies and practices that apply to the management of their personal information. This Privacy Policy is available on our web site at www.sunrype.com and can be accessed at any time. A hard copy of this Privacy Policy is also available at 1165 Ethel Street, Kelowna, BC V1Y 2W4. Sun-Rype reserves the right to modify this Privacy Policy at anytime without notice. The Privacy Policy posted at any time or from time to time via the Sun-Rype web site shall be deemed to be the Privacy Policy then in effect.
Although not listed in detail in this Privacy Policy, Sun-Rype will rely on any exceptions or qualifications that are set out in the applicable legislation as permitted by law.
- Individual Access
Upon request, Sun-Rype will inform an individual if Sun-Rype has any personal information about the individual under its care and control, as well as provide the individual with details about such personal information. Sun-Rype reserves the right to confirm the identity of the person seeking access to personal information before complying with any access request. In responding to an access request, Sun-Rype may charge a reasonable fee.
Sun-Rype is also committed to ensuring the personal information that is collected and maintained is accurate. An individual may challenge the completeness of the personal information under Sun-Rype's care and control. Where an individual successfully demonstrates that an error in the accuracy or completeness of their personal information exists, Sun-Rype will amend the personal information accordingly.
Sun-Rype may deny access to personal information when denial of access is required or authorized by law. Possible reasons for denying access to personal information include:
- when granting access would have an unreasonable impact on other people's privacy;
- to protect Sun-Rype's rights and property; and
- where the request is frivolous or vexatious.
If Sun-Rype is unable to provide access to all of the personal information it holds about an individual, then the reasons for the denial of access will be provided to the individual.
Requests for access to an individual's personal information may be made to the Chief Privacy Officer via email to privacy@sunrype.com or by telephone or in writing. The Chief Privacy Officer's complete contact information is as follows:
Gary Pearson, Chief Privacy Officer
Sun-Rype Products Ltd.
1165 Ethel Street
Kelowna, BC V1Y 2W4
Direct Telephone: 250-470-6570
Confidential Fax: 250-470-6485
- Challenging Compliance
Should you have any questions about Sun-Rype's Privacy Policy or have reason to believe that Sun-Rype may have failed to adhere to this Privacy Policy, you may contact our Chief Privacy Officer, Gary Pearson, at privacy@sunrype.com or at the afore-mentioned contact information.
