Collectively, we refer to the Website(s), emails, and offline business interactions as the “.”
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
We and our service providers collect Personal Information in a variety of ways, including:
Through the Services
From Other Sources
We and our service providers use Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our marketing materials and facilitating social sharing.
We will engage in this activity with your consent or where we have a legitimate interest.
Analyzing Personal Information for business reporting and providing personalized services.
We collect Personal Information from:
Allowing you to participate in sweepstakes, contests, or other promotions.
We use this information to manage our contractual relationship with you.
Aggregating and/or anonymizing Personal Information.
Accomplishing our business purposes.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
We disclose Personal Information:
To our third-party service providers, to facilitate the services they provide to us.
By using the Services, you may elect to disclose Personal Information.
Collection and Disclosure of Personal Information
The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.
|Categories of Personal Information||Disclosed to Which Categories of Third Parties for Operational Business Purposes|
|Identifiers, such as name, contact information, IP address and other online identifiers||Our affiliates; trusted third-party service providers; joint business partners; third-party sponsors of sweepstakes, contests, and similar promotions|
|Personal information as defined in the California customer records law, such as name and contact information||Our affiliates; trusted third-party service providers; joint business partners; third-party sponsors of sweepstakes, contests, and similar promotions|
|Characteristics of protected classifications under California or federal law, such as age and gender||Our affiliates; trusted third-party service providers; joint business partners; third-party sponsors of sweepstakes, contests, and similar promotions|
|Commercial Information, such as transaction information and purchase history||Our affiliates; trusted third-party service providers|
|Internet or network activity information, such as browsing history and interactions with our website(s)||Our affiliates; trusted third-party service providers; third parties, to permit them to send you marketing communications, consistent with your choices|
|Geolocation Data, such as device location and approximate location derived from IP address|
|Audio/Video Data. Audio, electronic, visual, and similar information, such as photographs and audio/video recordings||Our affiliates; trusted third-party service providers||Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, behavior, and characteristics||Our affiliates; trusted third-party service providers|
We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months. For example, and without limiting the foregoing, we do not sell the Personal Information of minors under 16 years of age.
We also use and disclose your Personal Information as necessary or appropriate, when we have a legal obligation or legitimate interest to do so:
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
We and our service providers may collect Other Information in a variety of ways, including:
Your browser or device.
Pixel tags and other similar technologies.
Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You will only receive emails from Nature’s Path if you opt in by signing up for our newsletter via our website, social media, an affiliated contest, or other platform. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out anytime by using the unsubscribe instructions provided in the footer of each email or on the site where you signed up to receive our marketing.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g. social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
We retain Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
THIRD PARTY PAYMENT SERVICE
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other website(s) or online services. You may receive advertisements based on information relating to your access to and use of the Services and other website(s) or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including using pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 3.
The site(s) are generally not intended for, nor targeted to, children under 13. We do not knowingly request or collect Personal Information from any person under thirteen (13) years of age through the site(s). If we are made aware that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with the applicable law.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE UK: Some countries are recognized by the European Commission as providing an adequate level of data protection (the full list of these “specified countries” is available here hyperlink to EU Commission’s adequacy list online: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. The UK recognizes the EEA and the specified countries as providing an adequate level of data protection according to UK standards. For transfers from the UK to countries not considered adequate by the UK government, we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information that we collect, use and disclose about California residents. This CCPA Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.
Use of Personal Information
Rights under the CCPA
If you are a California resident, the processing of certain personal information about you may be subject to the CCPA. Where the CCPA applies, this section provides additional privacy disclosures and informs you of key additional rights as a California resident. We will never discriminate against you for exercising your rights, including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.
Right to Know Request
Under the CCPA, California residents have a right to request information about our collection, use, and disclosure of your personal information over the prior twelve (12) months, and ask that we provide you free of charge with the following information:
Right to Delete Request
Under the CCPA, you also have a right to request that we delete personal information, subject to certain exceptions
Right to Opt-Out of the Sale of Personal Information
You may request that we not sell your Personal Information. Please note, however, that CCPA defines “sale” very broadly and includes “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California consumer’s Personal Information by the business to another business or third party for monetary or other valuable consideration.” We use services that help deliver interest-based ads to you and may transfer Personal Information to business partners for their use. Making Personal Information (such as online identifiers or browsing activity) available to these companies is considered a “sale” under the CCPA.
How to Exercise Your Rights
If you are a California resident to whom the CCPA applies, you may contact us to exercise your rights:
To request or delete data, complete this form.
Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. We may need to collect information from you to verify your identity, such as your email address, government-issued ID, or date of birth. You may make a verifiable consumer request to access your personal information twice per twelve (12) month period. We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:
If you are an authorized agent and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:
Under the Virginia Consumer Data Protection Act (“VCDPA''), Virginia residents are afforded certain rights regarding the data we have collected about them. This notice describes how we collect, use, and share your Personal Data in our capacity as a “Controller” under the VCDPA and the rights that you have with respect to your Personal Data, including sensitive personal data. For purposes of this section, “Personal Data '' and “sensitive Data '' have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope. In general, personal data is information reasonably linkable to an identifiable person.
Your rights under VCDPA
Right to Access Information/Correct Inaccurate Personal Data. You have the right to request access to Personal Data collected about you and information regarding the purposes for which we collect it, and the third parties and service providers with whom we share it. Additionally, you have the right to correct inaccurate or incomplete Personal Data. You may submit such a request as described below.
Right to Deletion of Personal Data. You have the right to request in certain circumstances that we delete any Personal Data that we have collected directly from you. You may submit such a request as described below. We may have a reason under the law why we do not have to comply with your request, or why we may comply in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Right to Opt-Out of Sale of Personal Data to Third Parties. You have the right to opt out of any sale of your Personal Data by Snow to third parties. We do not sell Personal Data to third parties for their own direct marketing purposes.
Right to Opt-Out of Targeted Advertising. You have the right to opt out of Targeted Advertising based on your Personal Data obtained from your activities over time and across websites or applications.
Right to Opt-Out of Profiling. You have the right to opt-out of having your Personal Data processed for the purpose of profiling in the furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to Appeal. If we decline to act on any request that you submit in connection with the rights described in the above sections, you may ask that we reconsider our response by sending an email to email@example.com that you receive the decision. You must ask us to reconsider our decision within 45 days after we send you our decision.
How to Exercise Your Rights
If you are a Virginia resident to whom the VCDPA applies, you may contact us to exercise your rights:
To request or delete data, complete this form.
Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. We may need to collect information from you to verify your identity, such as your email address, government-issued ID, or date of birth. We aim to fulfill all verified requests within 45 days pursuant to the VCDPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
Right to be informed
The amended Quebec Private Sector Act also includes more specific disclosure obligations for organizations, including requirements to indicate whether there is a possibility that an individual's personal information will be communicated outside of Quebec, and to provide individuals with the names of the third parties or categories of third parties to whom it is necessary to communicate their personal information.
Right to access
Under Canadian data protection laws, individuals have a general right to obtain access to their personal information held by organizations. Access requests must be processed in accordance with the applicable statute, within prescribed timeframes. Organizations are permitted to refuse access only in enumerated circumstances, and generally must sever exempt information from non-exempt information where possible. For example, under PIPEDA, organizations may refuse access to personal information where, among other exceptions, the information is protected by solicitor-client privilege or would reveal confidential commercial information.
Requests for access to personal information under data protection statutes are relatively infrequent in Canada but are on the rise. They often attempt to use such requests as a form of early litigation discovery by individual litigants and prospective litigants, including former employees. Organizations generally must process such requests, notwithstanding whether parallel litigation proceedings are in existence. Click here to request information.
Right to rectification
The OPC has taken the position, in the Draft OPC Position on Online Reputation, that under PIPEDA, individuals should have the ability to remove information that they have posted online and has suggested that PIPEDA currently includes this right in relation to the right to withdraw consent. The amended Quebec Private Sector Act gives individuals the right to demand that an organization cease dissemination of their personal information or de-index any hyperlink that provides access to their information by a technological means. In most other Canadian provinces, it is unsettled whether the right to erasure currently exists, or to what extent it exists. The OPC has asked the Federal Court in a case reference to clarify the law on this point.
Right to erasure
The OPC has taken the position, in the Draft OPC Position on Online Reputation, that under PIPEDA, individuals should have the ability to remove information that they have posted online and has suggested that PIPEDA currently includes this right in relation to the right to withdraw consent. The amended Quebec Private Sector Act will give individuals the right to demand that an organization cease dissemination of their personal information or de-index any hyperlink that provides access to their information by technological means. In most other Canadian provinces, it is unsettled whether the right to erasure currently exists, or to what extent it exists. The OPC has asked the Federal Court in a case reference to clarify the law on this point. You have certain rights in relation to your personal information. If you would like further information with respect to these rights or would like to exercise any of them, please fill out the data subject form here.
Right to object/opt-out
Individuals have the right to submit complaints to organizations, to withdraw consent (subject to some limitations), and to file complaints with the OPC. Based on guidance from the OPC, opt-out consents are permissible under PIPEDA in limited circumstances involving non-sensitive information provided that a set of requirements are met.
Right to data portability
There is no specific right to data portability under PIPEDA, AB PIPA, or BC PIPA. The amended Quebec Private Sector Act will give individuals a right to data portability by providing that individuals may request that their personal information be communicated or transferred to the person or a third-party organization in a structured and commonly used format, subject to certain limits. The Quebec Private Sector Act's data portability rights will come into force on 22 September 2024.
Right not to be subject to automated decision-making
There is no specific right not to be subject to automated decision-making under PIPEDA, AB PIPA, or BC PIPA. The amended Quebec Private Sector Act requires organizations that make decisions based exclusively on the automated processing of personal information to notify the person concerned that the decision was made in this manner, and to provide the individual with certain additional information concerning the decision-making process upon request.
Individuals have a range of rights pursuant to private sector privacy laws in Canada, many of which are linked to the rights of access, correction, and withdrawal of consent, and others which flow from the right to seek redress for violations of other requirements in the laws.
Because email communications are not always secure, please do not include credit cards or other sensitive information in your communications to us.
The Data Protection Office is appointed by Snow Commerce, Inc. ("Snow"), an Ohio Corporation with place of business at 1340 Clay Street, Cincinnati, OH 45202. You may lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. Information regarding the UK data protection authority is available here: https://ico.org.uk/.