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Privacy Policy

Last updated: July 12, 2019.

We at VIT-ASSESS INC. (“VIT-ASSESS,” “we,” “us,” or “our”) have created this privacy policy because we know your information is important to you and you care about how it is used or shared. This Privacy Policy relates to the information collected by VIT-ASSESS in relation to all our Services which are found at VIT-ASSESS.com (the “Website”).

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to the Website who view only publicly available content (“Visitors”), and customers who have purchased our Services (“Customers”).

By visiting our Website or using our Services, you agree to the terms of this Privacy Policy and our Terms of Use. If you do not agree to the terms of the Privacy Policy, you should stop using our Services or visiting our Website immediately.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

The Information We Collect and/or Receive

In the course of operating the Website, and the Services, VIT-ASSESS will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1.            Personal Information:

In order for us to provide you with an assessment Service, you will be asked to provide us with personal information about yourself, such as your first name, e-mail address, gender, age and address. All information that we receive under this section is collectively called “Personal Information.” We do not collect any Personal Information from Visitors when they use the Website, unless they provide such information voluntarily.

2.            Wellness Information:

In order to undergo one of our assessment Services, you will be asked to provide us with some information about your health and wellness, including but not limited to your diet, your lifestyle, medical conditions that you have experienced and symptom-related questions about your macronutrients, digestive imbalances, excesses, macro minerals, micro minerals, fat-soluble vitamins, water-soluble vitamins, other nutrients, toxic metals, glandular imbalances, and metabolic/systemic imbalances (collectively, the “Wellness Information”).

3.            Billing Information:

In order to purchase one of our assessment Services, you will be required to provide certain information in addition to the Personal Information noted above. Such information may include a credit card number, expiration date, billing address, activation code, promotional code and similar information (collectively, the “Billing Information). Such Billing Information will be collected and processed by our Third Party Payment Vendor pursuant to the terms and conditions of their privacy policies and terms of use, and we do not obtain access to any Billing Information.

4.            Assessment Information:

When Customers complete their assessment Service, we will also collect certain information, including but not limited to, the choice of assessment and the customer’s responses to the assessment itself (“Assessment Information”).

5.            Other Information:

In addition to the Personal Information, Wellness Information, Assessment Information, and the Billing Information, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:

A.            From Your Activity:

In an ongoing effort to improve the Website and the Services, we automatically collect certain information when Visitors visit the Website, and when Customers use the Services. Such information includes, without limitation, IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website Visitors visit, and similar information concerning your use of the Services.

B.            From Cookies:

We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Services. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Services may not function properly.

C.            Third-Party Analytics:

We may use one or more third-party analytics services (such as Google Analytics) to evaluate your use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. These third parties may change from time to time.

The Information Collected by or Through Third-Party Advertising Companies

We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Website over time so that they may play or display ads on our Website, on other devices you may use, and on other websites, apps or services, including on Facebook. It is important to note, however, that we do not share any of your Personal Information with these parties. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect this non-personal information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. You may opt-out of the tailoring of advertising based on information we collect. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance’s resources atwww.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings.

How We Use and Share Information

You authorize us to use the Personal Information, Wellness Information, Assessment Information and the Other Information (collectively, the “Information”) to provide and improve the Website and the Services; to solicit your feedback; and to inform you about our products and services and those of our promotional partners.

You also authorize us to use and/or share Information as described below.

             Agents, Providers and Related Third Parties:

We may engage other companies and individuals to perform certain business-related functions on our behalf. Examples may include providing technical assistance, order fulfillment, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law. We may also share your Information with any of our parent companies, subsidiaries, or other companies under common control with us.

             Aggregated Information:

In an ongoing effort to better understand our Visitors, and Customers, we may analyze Personal Information with Other Information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Website and the Services and for our own research purposes. This aggregate information does not identify you personally.

             Business Transfers:

As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

             Legal Requirements:

We may disclose your Information if required to do so by law, or in the good faith belief that such action or disclosure is necessary or appropriate to: (i) operate the Platform, (ii) comply with any legal obligation, report unlawful activity, cooperate with law enforcement, or protect against legal liability, (iii) protect and defend our rights, property, personnel, suppliers, sponsors, agents or licensors, or (iv) protect the personal safety of vendors, users of the Platform or the public.

We know how important it is to keep the Information you’ve entrusted to us confidential. We will not rent, sell or share your Information with third parties except as specifically approved or under the circumstances described above. If you do not want us to use or disclose Information collected about you in the ways identified in this policy, you should not use the Website or Services.

             Assessment Results:

Your Assessment Information may also be reviewed by a qualified employee of VIT-ASSESS to ensure proper results are being reported to you.

How We Protect Your Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We follow generally accepted industry standards to protect the Information submitted to us, both during transmission and once we receive it. However, we cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Modifying Information and Communication Preferences

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any VIT-ASSESS marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. Customers cannot opt out of receiving transactional e-mails related to their account with VIT-ASSESS.

Important Notice to Non-Canadian Residents

The Website, the Services, and their servers are operated in Canada. Please be aware that your information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside Canada and choose to use the Website and/or the Services, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in Canada and elsewhere.

External Websites

The Website and the Services may contain links to External Sites. VIT-ASSESS has no control over the privacy practices or the content of these External Sites. As such, we are not responsible for the content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Children

We do not knowingly collect Personal Information from children under the age of 13. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide us Personal Information without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

Opt-Out and Data Retention

In addition, VIT-ASSESS does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

General Data Protection Regulation (“GDPR”)

As of May 25, 2018, the EU General Data Protection Regulation (“GDPR”) went into effect through the EEA countries and Switzerland. The GDPR requires that companies provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data.

To comply with GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please don’t rely on the below, if you’re not):

  1. Legal grounds for processing your Personal Data

GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out in the section entitled Information Collection and Use will typically be because:

  • You provided your consent. In order to provide our Services that involve use of precise location information related to other Personal Data, (and to store and gain access to information stored on your device such as Device IDs), we rely on your consent. To obtain this consent, we rely on our own compliance steps and our web and mobile partners’ compliance steps, designed to ensure that consent is collected and passed on to partners, and to ensure that we only facilitate the collection of legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal. We also seek to obtain consent for certain partners with whom we work, who are often independent data controllers. A list of our Trusted Partners, if any, can be found on our Website.
  • The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed. We also rely on legitimate interest when we use our own customers’ data (or Visitors’ data) to communicate with them about our Services or analyse our own Site activity.
  • Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);
  • Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
  1. Transfers of Personal Data

When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. In general, our data transfers of our Personal Data are safeguarded by European Standard Contractual Clauses and Data Processing Agreements where this is required by European Data Protection Law. Feel free to contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

As VIT-ASSESS works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.

  1. Personal Data Retention

As a general matter, we retain your Personal Data for as long as necessary to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. Please note that we may retain this (and other) Information whenever and so long as we have a significant legal or operational need to do so, such as for repeat assessments, auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.

If you are a customer of ours and thus have an account with us, we will typically retain your Personal Data for as long as required in order to serve the purpose for which it was collected, such as to provide you relevant information about our products and services.

  1. Your Rights as a Data Subject

The GDPR provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting):

  • Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the e-mail address info@vit-assess.ca with the subject line “PRIVACY POLICY”. When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. As we are required to verify a requestor’s identity prior to providing Personal Data, we will assess requests to exercise certain data access rights on a case-by-case basis: in doing so, we consider (a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with (b) the potential adverse effects on disclosure of personal data to the wrong individual. Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the data subject, we may limit the Personal Data we make available. Please note that we will only grant requests for access for Personal Data for which we are a data controller, as explained further in sub-section (e) below. Where we act as a processor for one of our customers, we will refer your request to that customer. Please identify the customer your request refers to (if possible), to simplify this process.
  • Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
  • Right to Object to Processing or to Withdraw Consent: By using “opt-out” signals described in this Privacy Policy, you may withdraw consent for processing on which we rely on consent. If you do so, we will cease processing your Personal Data for purposes of our services within 30 days or less. We either collect these opt-out signals ourselves or receive them from our partners.
  • Right to Erasure. You also have the right to obtain the erasure of Personal Data concerning you that we hold as a controller. The above opt-out process satisfies this right. When a user opts-out through our partners, and we receive this signal, we no longer use Personal Data to provide our advertising services. We will also manually delete your Personal Data if you prefer that we do so; please contact us and email your device to info@vit-assess.com with the subject line “PRIVACY POLICY” for further instructions if you wish to exercise this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our certain important internal and purposes, such as auditing, accounting and billing, legal or bug-detection, for as long as is necessary to fulfill those purposes.
  • Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.
  1. VIT-ASSESS as a data controller and a data processor

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). There may be situations where we are not always the data controller of the data in our possession, but are a data processor for other companies. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Website. If we make any material changes, we will notify you by email (sent to the email address specified in your account) prior to the changes becoming effective. By accessing the Website and/or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please contact VIT-ASSESS via e-mail at info@vit-assess.com with “Privacy Policy” in the subject line.

VIT-ASSESS INC.
Bolton, Ontario, Canada

Copyright 2019 VIT-ASSESS INC. All rights reserved.