Privacy Policy

Nature’s Path Foods, Inc., our affiliates, and our family of brands that includes Nature’s Path, EnviroKidz, Love Crunch, Anita’s Organic Mill and Que Pasa and our distributor Simple 2 Partners LLC (collectively, “Nature’s Path,” “we,” “our” or “us”) want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

• Website(s) operated by us from which you are accessing this Privacy Policy (the “Website(s)”);
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and offline business interactions you have with us.

Collectively, we refer to the Website(s), emails, and offline business interactions as the “Services”.

1. Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

• Name
• Physical address
• Email address
• Telephone number
• Account user ID and password
• Products purchased, including order numbers
• IP address (we may also derive your approximate location from your IP address)
• Payment card information for website orders and subscription accounts.

2. Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

Through the Services

• We collect Personal Information through the Services, for example, when you register an account to access the Services, sign up to receive our emails, give us feedback, participate in any of our surveys, contests or other promotions, or contact customer support, or make a purchase.

From Other Sources

• We receive your Personal Information from other sources, for example, our affiliates, publicly available online sources, joint business partners, and third-party advertising and market research partners.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

3. Use of Personal Information

We and our service providers use Personal Information for the following purposes:

Providing the functionality of the Services and fulfilling your requests.

• To provide the Services’ functionality to you, such as arranging access to your registered account, completing your transactions, and providing you with related benefits, special promotions, or customer service.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments, or complaints, or when you request information about our Services.
• To send administrative information to you, such as changes to our terms, conditions, and policies.

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.

• To send you marketing related emails, with information about our services, new products and other news about our company.
• To facilitate social sharing functionality that you choose to use.

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.

• Nature’s Path may use information collected through the site(s), including personal information and for various purposes, which may be more explained in notices at or before collection of any specific information, including but not limited to:
• Allow you to use the site(s) and to provide you related service, including providing support and respond to questions from customers, address information security and/or privacy issues, fulfill, respond to, and document privacy rights requests, network functioning, and troubleshooting, contact you with administrative communications and, in our discretion, changes to site(s)’ policies.
• Fulfill transactions and process your registration, orders, and payments, including verifying the information you provide is accurate and active or to remember and restore your preferences when you return to the site(s).
• Administer and develop our business relationship with you and the company you represent.
• Assess your employment application for a position with Nature’s Path and prepare related governmental and internal statistics reports.
• Personalize your online experiences and tailor content, recommendations and offers we display to you on the site(s) and elsewhere online.
• Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you, including information and special offers from us, our advertisers, and our third-party business partners.
• Conduct internal analyses, such as surveys, studies, and market research and improve the site(s), our products, and services and for internal business purposes and monitor and analyze trends, usage, and activities of visitors and users of the site(s).
• To comply with applicable laws, regulations, or legal process as well as industry standards and our company policies,
• Investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant applicable laws and legal process.
• Prevent, investigate, identify, or take any other action regarding suspected or actual fraudulent or illegal activity, or any activity that violates our policies.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred; Such other purpose you may consent.
• We may collect, use, and disclose your personal information as required or permitted by applicable law. We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements.

We collect Personal Information from:

• Our interactions with you, such as when you interact with our website(s) or other online services we provide, give us feedback, participate in any of our surveys, contests, or other promotions, link your social media account to your account with us, or contact customer support; and
• Our affiliates, publicly available online sources, joint business partners, and third-party advertising and market research partners.

Allowing you to participate in sweepstakes, contests, or other promotions.

• We may offer you the opportunity to participate in a sweepstakes, contest, or other promotion.
• Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.

We use this information to manage our contractual relationship with you.

Aggregating and/or anonymizing Personal Information.

• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

Accomplishing our business purposes.

• For data analysis, for example, to improve the efficiency of our Services.
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
• For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
• For developing new products and services.
• For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

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.

4. Disclosure of Personal Information

We disclose Personal Information:

To our affiliates for the purposes described in this Privacy Policy.

• You can consult the list and location of our affiliates here:
• Simple 2 Partners LLC, United States; Power Reviews, United States; Recharge, United States; Shopify, Canada; Midwest Ryder, United States; Cairns O’Neil, United States, JD Smith, Canada; CDS, Canada

To our third-party service providers, to facilitate the services they provide to us.

• These can include providers of services such as website hosting, data analysis, fraud prevention, payment processing, order fulfillment, return authorization, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
• To third parties, to permit them to send you marketing communications, consistent with your choices.
• Simple 2 Partners LLC, United States; Power Reviews, United States, Recharge, United States, Shopify, United States, Google Analytics, United States.
• To third party sponsors of sweepstakes, contests, and similar promotions.

By using the Services, you may elect to disclose Personal Information.

• On message boards, blogs, user generated social media content and other services to which you can post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

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	Our affiliates; trusted third-party service providers; joint business partners; third-party sponsors of sweepstakes, contests, and similar promotions
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.

5. Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
• This may include laws outside your country of residence.
• To cooperate with public and government authorities.
• To respond to a request or to provide information we believe is necessary or appropriate.
• These can include authorities outside your country of residence.
• To cooperate with law enforcement.
• For example, when we respond to law enforcement requests and orders or provide information, we believe it is important.
• For other legal reasons.
• To enforce our terms and conditions; and
• To protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
• We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

6. OTHER Information

“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:

• Browser and device information
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

7. Collection of Browser Data

We and our service providers may collect Other Information in a variety of ways, including:

Your browser or device.

• Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.

Cookies.

• Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected using cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

Pixel tags and other similar technologies.

• Pixel tags Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
• Analytics We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information regarding the use of other website(s), apps, and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/‌partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• We use Google’s invisible reCAPTCHA application on our Services to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements. The use of the reCAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.

Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.

• We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
• We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content.] [We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

8. How do we share Personal Information?

We do not sell, trade, or otherwise transfer Personal Information about you to outside parties unless we provide you with advance notice, except as described below. “Outside parties” does not include website hosting partners, distributors (including but not limited to Simple 2 Partners, LLC) and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety.

Personal Information may be disclosed to a third party in connection with a merger, acquisition, asset sale, or similar transaction. Personal information may be shared with a third party to provide, maintain, or improve customer products and services and customers might request the list of such third parties by writing an email to .

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information if it is combined.

9. Security

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.

10. Choices and Access

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.

RETENTION PERIOD

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:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services).
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them); or
• Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation, or regulatory investigations).

11. Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

THIRD PARTY PAYMENT SERVICE

The Services may provide functionality allowing you to make payments to us using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such a third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

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.

If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit https://www.naturespath.com/faqs/.

Microsoft Clarity

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.

12. Use of Services by Minors

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.

There are some site(s) pages that may be intended for certain audiences that may include certain age ranges, in which case we may provide additional or separate privacy notices to address those specific audiences. Additionally, those sites will indicate the child under thirteen (13) to request adult support to view and access the content. Such privacy notices may clarify further the data collected through the applicable site(s) and should such audience-specific privacy notices contradict this Privacy Policy, the audience-specific privacy policy shall govern for the stated specific audience.

13. Jurisdiction and Cross-Border Transfer

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.

14. California Consumer Privacy Act

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:

1. the categories of personal information about you that we collected.
2. the categories of sources from which the personal information was collected.
3. the purpose for collecting personal information about you.
4. the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
5. the specific pieces of personal information we collected about you. Email  privacynp@simple2partners.com to request data.

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, email privacynp@simple2partners.com.

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.

Authorized Agents

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:

1. Proof of your registration with the California Secretary of State to conduct business in California.
2. Proof of power of attorney from the resident pursuant to Probate Code sections 4121-4130.
3. Signed permission that the resident has authorized you to make a request on the resident’s behalf.

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:

1. Verify the resident’s own identity directly with us; or
2. Directly confirm with us that the resident provided you with permission to make the request.

15. Virginia Consumer Data Protection Act

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.

The chart found within this Privacy Policy describes the categories of Personal Data that we collect about you. However, the type of Personal Data collected will depend upon how you interact with our Sites and the information you voluntarily provide us. Accordingly, we may not collect all the information listed in the chart from you. In addition, we may collect and/or use additional types of information after providing notice to you and obtaining your consent to the extent the VCDPA requires such notice and consent.

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 to third parties. We do not sell Personal Data to third parties for their own direct marketing purposes.

Right to Portability. You have the right to request a copy of the Personal Data that you previously provided to us as a Controller in a portable format. Our collection, use, disclosure, and sale of Personal Data are described in our Privacy Policy. Email  privacynp@simple2partners.com to request data.

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 privacynp@simple2partners.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, please email privacynp@simple2partners.com.

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.

16. Personal Information Protection and Electronic Documents Act (Canada)

Right to be informed

Canadian private sector privacy laws generally require the knowledge and consent of the individual, except in certain circumstances where consent is not required. Organizations must be open and transparent about their practices and inform individuals about the information collected, used, and disclosed, as well as the purposes for such activities, among other requirements. One way that organizations meet this obligation is through a public-facing privacy policy; this will soon be a statutory requirement for all organizations collecting personal information using technological means in Quebec.

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. Email  privacynp@simple2partners.com 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 email privacynp@simple2partners.com.

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.

Other rights

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.

17. Contact

Nature’s Path Foods, Inc., located at 9100 Van Horne Way, Richmond, BC V6X 1W3, Canada, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at consumerservices@naturespath.com or at 9100 Van Horne Way, Richmond, BC V6X 1W3, Canada.

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 Simple 2 Partners LLC (United States). 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/.