Privacy Policy - Reform Pharma Now

Privacy Policy

Effective Date: November 3, 2023

Reform Pharma™ (also referred to as “our”, “us”, and “we”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website reformpharmanow.org (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy is structured so you can easily scroll to the specific areas set out below.

Important Information and Who We Are

Purpose of this Privacy Policy

This Privacy Policy provides information on how Reform Pharma™ collects and processes your personal data through your use of and interaction with our Website (located at www.reformpharmanow.org and referred to as the “Website”), including any data you may provide through our Website, for example when you sign up to receive our newsletter, purchase a product, or take part in a survey.

When this Privacy Policy mentions “personal data” or “personal information”, it means data that, alone or in combination with other data we collect, could identify you as a natural person. It does not include data where the identity has been removed or otherwise rendered unreadable, i.e., anonymous data.

Please read this Privacy Policy carefully before you start to use the Website or provide us any information about yourself. By using the Website or by accepting or agreeing to the Terms of Use when this option is made available to you, you accept and agree to be bound and abide by this Privacy Policy, our Terms of Use found on the Website, and any other additional privacy terms applicable to your geographic location. If you do not want to agree to these Terms of Use or the Privacy Policy, you must not access or use the Website or otherwise provide us any information about yourself as this Privacy Policy, together with our Terms of Use, creates a binding agreement between you and us in regards to the matters covered in those policies.

Eligibility

We do not knowingly collect personal data from anyone under the age of 13 (16 in the EU/EEA/UK). If you are a parent or guardian and you are aware that your child has provided us with personal information, please email us at [email protected]. If we become aware that we have collected personal information from anyone under the age of 13 (16 in the EU/EEA/UK) without verification of parental consent, we will take steps to remove that information from our servers.

Controller

Reform Pharma™ is an initiative of Children’s Health Defense: a 501(c) (3) charitable, non-profit organization (Tax ID number: 26-0388604). Reform Pharma™ is the controller with respect to your data, and responsible for this Website. When you donate, you are donating to Reform Pharma™. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, including any data subject rights you may have based on where you reside, please contact the data privacy manager using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Children’s Health Defense c/o Reform Pharma™

Email address: [email protected]

Postal address: 852 Franklin Ave, Suite 125, Franklin Lakes, NJ 07417

Telephone: (404) 941-6515

If you are based in the European Union (“EU”), European Economic Area (“EEA”), or the United Kingdom (“UK”), you can locate information about your data subject rights in the EU/EEA/UK Resident Rights section, below. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) located in the member state in which you reside for purposes of EU/EEA resident data protection issues and with the UK supervisory authority for purposes of UK residents’ data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the relevant ICO so please contact us in the first instance.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our Privacy Policy under regular review. Historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may update our Privacy Policy from time to time. We will email you about the changes and when they will go into effect. Modifications to this Privacy Policy are effective when they are posted on this page. In the event material changes are made to this Privacy Policy you will be asked to renew your acceptance of this Privacy Policy the next time you login to your account on our Website. If required, we will obtain your consent before the changes go into effect.

Third-Party Links

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their data collection, use, disclosure or related practices. We advise you to review their privacy statements and policies to learn more about their data collection, use, disclosure or related practices. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, your interests, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Story Data includes information you share about your experiences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under the law as this data does not and will not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Policy.

We collect the following Special Categories of Personal Data about you: information about your health and vaccination status. We do not collect any other Special Categories of Personal Data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Contact Data and Story Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

make a donation or purchase products or services;
create an account on our Website;
subscribe to our service or publications;
request marketing information to be sent to you;
enter a competition, promotion or survey; or
give us feedback or otherwise contact us.

Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the Cookies section below for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

analytics providers based inside and outside the EU;
advertising networks based inside and outside the EU; and
search information based providers inside and outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.

How We Use Your Personal Data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we may use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user	(a) Identity(b) Contact	Performance of a contract with you
To process and deliver your order including:(a) Manage payments, fees and charges	(a) Identity(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity(b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organization or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

We may also use the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in our Privacy Notices.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Promotional Offers From Us

We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We do not currently sell, rent, lease, disclose or otherwise share your personal data with any third party for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we disclosed to you in this Privacy Policy or via other communication, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose for which we collected it. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of Your Personal Data

We do not share (for purposes of cross behavioral marketing), sell, rent, lease, release, disclose, disseminate, make available, transfer or otherwise communicate orally or in writing or by electronic or other means your personal information to any other business outside our group of companies, or to any third parties for monetary consideration, including to opt you into a financial incentive program and have not in the last 12 months or at any time after January 1, 2023. In the event we do, we will request your consent prior to doing so.

We do not share your personal data with third parties except with:

Internal Third Parties, which include our related entity, Children’s Health Defense.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy and they will also be under confidentiality agreements that provide for contractual protections of your personal data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our written instructions.

International Transfers

We share your personal data within the Reform Pharma™ Group. This will involve transferring your data outside the EU, EEA, and/or UK.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. As such, to the extent we transfer data from the EU, EEA, and/or UK to a jurisdiction without an adequacy decision, we will ensure that it is done so through a Data Processing Addendum with the proper Standard Contractual Clauses as approved by the European Commission and/or the ICO, which give personal data the same protection it has in the EU, EEA, and/or the UK. For further details, see European Commission: Standard contractual clauses for international transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place security measures to help prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you access our Website and provide us with your information at your own risk.

Data Retention

How long will you use my personal data?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymize your personal data, so that it can no longer be associated with you, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Privacy Rights

EU/EEA/UK Resident Rights

If you reside, or resided within the EU, EEA, or UK during the time you accessed our Website or otherwise provided us any personal data, you have the following rights:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to determine if you are eligible to exercise any of the rights and, if so, exercise any of the rights set out above, please contact us and, in your subject line indicate that your contact is “Data Subject Request” and provide us information about what data subject right(s) you would like to access so we can begin the data subject response process.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to clarify your request and/or to help speed up our response.

We try to respond to all verifiable, legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) located in the member state in which you reside for purposes of EU/EEA resident data protection issues and with the UK supervisory authority for purposes of UK resident’s data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the relevant ICO so please contact us in the first instance as set forth above.

Colorado Resident Rights

If you are a Colorado resident, you have the following rights under applicable Colorado law in relation to your personal information, subject to certain exceptions:

Right of Access. You have the right to confirm whether we collect Personal Information about you and, if so, what Personal Information we collect, use, disclose, and/or sell, as applicable.
Right to Delete. You have the right to request the deletion of your personal information that is collected by us.
Right to Correct. You have the right to request that we correct inaccuracies in the personal information that we collect about you.
Right to Opt-Out of Sale. You have the right to opt-out of the sale of your Personal Information to third parties for the purpose of targeted advertising, profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer or for monetary return. You may authorize another person acting on your behalf to opt out of the processing of your personal data for any of the reasons set forth above. However, as noted above, we do not currently sell any personal information.
Right to Data Portability. No more than two times per calendar year, you have the right to request a copy of your personal information we have collected and maintained about you that allows you to transfer the data to another entity.

Any request you submit to us to know, to delete or to correct is subject to an identification and residency verification process as permitted by Colorado law. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information.

This section describes your Colorado data subject rights and explains how to exercise those rights and also describes various exclusions and exceptions under Colorado law.

We will respond to your request within 45 days after receipt of a Verifiable Consumer Request for a period covering 12 months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. We will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

You may submit data subjects requests to know two times within any 12-month period. We can deny more frequent requests. There are no limits on the number of deletion or correction requests you can make. However, we may deny or charge a fee for manifestly unfounded or excessive deletion requests in line with our administrative costs for the deletion requests.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Within 45 days of a valid and verifiable data subject request, if we do not take any action on the request, we will let you know why, which is usually because we cannot verify your identity or we have verified your identity but identified that you are not and have not been a Colorado consumer in the relevant time period and not able to exercise rights under the CPA. We will provide information about how you may appeal this decision / non-action in that communication.

You may contact the Colorado Attorney General if you have concerns about the result of your appeal.

We will not process personal information in violation of state or federal laws that prohibit unlawful discrimination against consumers.

We will not discriminate against you for exercising any of your CPA rights. Unless permitted by the CPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

For United States Resident Users

Do Not Track

(Including California and Delaware Do Not Track Disclosures)

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, we do not currently interpret, respond to or alter our Website’s practices when it receives “Do Not Track” signals.

Consent to Receive Electronic Notifications

Electronic communication is the most effective and timely way to provide the users of the Website and Services with any optional or required notifications and disclosures. In some circumstances, however, applicable laws may require us to send you disclosures or communications in paper format unless you have affirmatively consented to receiving electronic notifications only in advance of the notification. Through this Privacy Policy, pursuant to 15 U.S.C. § 7001, you hereby affirmatively consent to receive electronic notifications and disclosures from us only (without requiring a paper copy) and you represent that, to date, you have not withdrawn such consent. You have the right to change your mind and withdraw your consent at any time. If you would like to withdraw your consent to receive electronic notifications and/or would like to request paper copies of any required notifications you receive electronically, you may contact us by email at [email protected], or by mail at 852 Franklin Ave, Suite 125, Franklin Lakes, NJ 07417. To receive electronic records, you will need access to a smartphone, tablet, laptop or computer with internet access and an email account.

Notice to Nevada and Utah Residents

We do not disclose a user’s personal data to any third party for such third-party’s direct marketing purposes. Nevada S.B. 220 allows Nevada residents to opt-out of the sale of their personal information now in the event we change our Privacy Policy in the future. If you are a Nevada resident we want you to know that, in the event we sell your Personal Information, you will have choices and can opt out and can affect them by contacting us at [email protected] or via mail at Privacy Officer, 852 Franklin Ave, Suite 125, Franklin Lakes, NJ 07417. This may prevent or restrict your use of the Services in the future.

Notice to Delaware Residents

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our Website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Notice to Virginia Residents

We are not subject to the Virginia Consumer Data Protection Act as we are a non-profit entity.

Notice to California Residents

We are not subject to the California Consumer Data Privacy Act as we are a non-profit entity.

For Canadian Resident Users

Canadian Anti-Spam Legislation (CASL)

This Section provides additional information regarding the use of Personal Information about Canadian residents and the process to be followed in order to send unsolicited electronic communications to them, and our responsibilities under CASL.

For the purposes of this section:

Commercial activity: Any transaction of commercial character, regardless of whether there is an expectation of profit or not.
Commercial electronic message (“CEM”): CEMs are commercial electronic messages that encourage participation in commercial activity. Even if a commercial message is not sent with an expectation of garnering profit, it still qualifies as a CEM.
Electronic address: An address used in connection with the transmission of an electronic message to an electronic mail account, an instant messaging account, a telephone account or similar account.
Electronic message: A message sent by any means of telecommunication, including text, sound, voice or image.
Express consent: Permission obtained when a recipient “opts in” to receive CEMs. Consent can be oral or written and could be an unedited audio recording, paper or electronic checkbox on a website. Express consent never expires unless the recipient chooses to unsubscribe. We will maintain records of all contacts for whom express consent exists.
Unsubscribe: A withdrawal of consent to receive CEMs

By submitting forms to us that provide your electronic address, you are granting us express consent to send you CEMs. You may unsubscribe via the link found at the bottom of every electronic message.

All partners, employees, contractors, vendors and any other person sending CEMs on behalf of us will ensure that all such CEMs contain:

Full contact information. This includes the sender’s first name, last name, title, company name, company mailing address, direct telephone number, electronic address and company web address.
Information enabling you to contact us and, if the CEM is sent on behalf of another party, the name of this party and the sender, in addition to the information listed above.
An unsubscribe link that is clearly visible and that is valid for at least 60 days. The unsubscribe mechanism that will be provided to users via this link will be simple, quick and easy for the user to perform.

Unsubscribe Requests: All unsubscribe requests will be managed within 10 days of receipt. Partners, employees, contractors, vendors and any other person sending CEMs on behalf of us will not send an unsubscribed party any further communications by electronic means.

When we plan to introduce significant changes to our privacy practices, we will notify Canadian-resident users and obtain their consent prior to the changes coming into effect. Significant changes include using Personal Information for a new purpose not anticipated originally or a new disclosure of personal information to a third party for a purpose other than processing that is integral to the delivery of a service.