Last Revised: August 2019
Orgali Holistic Nutrition Inc. (“Orgali”) offers holistic nutritional consulting services (the “Services”). Orgali receives, retains, and safeguards information in the course of providing the Services to any individual who is a client of Orgali (a “Client”). Some of the information Orgali receives is Personal Information relating to Clients as defined below.
Purpose and Definitions
This policy describes Orgali’s Personal Information management practices including in relation to providing the Services from Orgali, browsing the Orgali website (the “Site”), and subscribing to the Orgali newsletter. More specifically, this policy describes the purposes for which Orgali collects, uses and discloses personal information, including personal health information, of a Client, or other visitors to, or users of, the Site.
In this policy, “Personal Information” means information about an identifiable individual, such as a Client, including information relating to the individual’s physical health, mental health, health history, health care providers, health number, heath care services, or agent for healthcare (“Agent”). In this policy, an Agent is a person who is authorized to assist an individual to obtain healthcare and related services or make decisions about healthcare, including a substitute decision maker, a legal guardian, a person exercising a power of attorney or a person who is acting on the individual’s behalf with the individual’s consent.
Orgali reserves the right to amend this policy in response to changes in the Services, changes in Applicable Law as defined below, or changes in policies applicable to the Services. The date on which this policy was last amended is shown at the top of this policy. You are responsible for verifying whether amendments have been made to this policy. As in the Orgali Website Terms and Conditions, located at www.orgali.com/terms, your access to the Site or use of the Services after amendment of this policy will be understood to be your agreement to Orgali Website Terms and Conditions and the collection, use and disclosure of your Personal Information in accordance with the amended policy.
Orgali’s Legal Obligations
Orgali has obligations as a holistic nutritional consultant. Orgali’s obligations are based on applicable federal, provincial or local law as may be appropriate in the context, including consumer protection legislation, privacy legislation, the Food and Drugs Act (Canada), other statutory law and regulations, the Civil Code of Québec, common law, and any other applicable laws (collectively or in any combination, “Applicable Law”). These obligations include limits on the collection and disclosure of certain Personal Information. No agreement between you and Orgali can override a legislative requirement to collect, use or disclose your Personal Information and to retain your Personal Information for a specified period of time.
In addition to the Personal Information we are required to collect, you may voluntarily provide us with additional Personal Information, for example relating to medical conditions. With your express consent, we will use such Personal Information provided by you for medical or market research, education, improving our product offerings, or otherwise improving the experience of our Clients.
Collection, Use, and Storage of Personal Information
Orgali collects and uses Personal Information in the course of providing the Services. Once Orgali receives Personal Information, the Personal Information is stored digitally or in hard copy. All hard copies are stored in securely in Alberta and digital records of personal information are stored on encrypted drives located in Alberta.
Disclosure of Personal Information
Orgali may also disclose your Personal Information for the purposes of a court, administrative, or other proceeding to which it is a party, as permitted by applicable law.
If Orgali is required to disclose Personal Information pursuant to a court order, subpoena, warrant or other legal requirement, or discloses your Personal Information for the purposes of a court, administrative, or other proceeding to which it is a party, Orgali will not disclose any more Personal Information than required for the purpose and will, to the extent permitted by law, provide you with notice of the disclosure. There are circumstances, for example where a criminal investigation is in progress, where Orgali may be prohibited from notifying you of a disclosure obligation.
Personal Information of Visitors to the Orgali Website
When you visit the Site, we may collect technical information, which may include the address of the Site that you visited before visiting the Orgali Site, the pages of the Site that you visit, the browser you used to view the Site, the search terms you entered on the Site, and other such technical data (“Technical Information”). The Technical Information may not in itself constitute Personal Information.
We aggregate the Technical Information we collect from visitors to the Site and use the aggregate Technical Information to measure and improve the effectiveness of the Site and improve its content and responsiveness to visitor interests. We will not combine the Technical Information with any Personal Information we have collected. For clarity, the aggregate Technical Information we produce in relation to use of the Site does not identify individual visitors.
We may disclose the aggregate Technical Information about the use of the Site to our service providers, regulatory bodies, and others.
We may also use services such as Google™ Analytics and other forms of cookies on our website that collect information about users of our website to tailor marketing information to them. We will not collect Personal Information about you in this way or for this purpose without your consent.
Subscribing to the Orgali Newsletter and Other Communications
Orgali publishes a newsletter and provides other mass communications about special offers, product information, or other messages related to Orgali, to food more generally, or other topics. The Orgali newsletter and other mass communications are available to the public generally and there is no requirement to be a Client to receive the Orgali newsletter and other communications. If you are a Client, the Orgali newsletter and other mass communications do not identify you as such. Please note that separate from the Orgali newsletter and any mass communications, Clients may also receive specific communications relating to status as a Client, including recipes and special offers.
You may subscribe to the Orgali newsletter or consent to receive other mass communications through the Site. Subscribers may terminate their subscription at any time. The materials and notices we send by email include simple instructions and a link for you to unsubscribe. If you have any trouble unsubscribing, please contact our Privacy Officer as set out below.
Access and Correction of Personal Information, and Other Inquiries
You may request access to and the correction of your Personal Information in our records. You may request confirmation of the location of your Personal Information. Except in circumstances established by law, you have a right to access any of your Personal Information in our records. To the extent that we are satisfied that your Personal Information in our records is inaccurate, we will correct the information.
If you want clarification of this policy, additional information about our Personal Information management practices or our management of your Personal Information, or if you want us to investigate any concerns you have about our use or disclosure of your Personal Information, please contact our Privacy Officer as set out below. Please note that email is not a secure means of communication. You assume all risk in relation to your decision to transmit Personal Information or confidential information to us by email, or to receive communications from Orgali by email.
Contact for Orgali Privacy Officer:
Email: [email protected]
Attention: Privacy Officer
For inquiries unrelated to privacy, please contact [email protected].