This privacy policy (the “Privacy Policy”) sets out how Tree of Life Canada, ULC (“Tree of Life”, “we”, “us”, or “our”) collects, uses, and discloses, personal information (as described in this Privacy Policy) that you give us or that we collect when you use https://treeoflife.ca/ (the “Website”), use our Services (as defined below), or otherwise interact with us.

Tree of Life is one of Canada’s leading curator and growth partner for the food and beverage industry, from end to end. We offer the Website as a platform to provide information to visitors about our products and brands, and to allow companies that may wish to work with us and sell or distribute our products to find more information about doing so (collectively, the “Services”).

To the extent permitted by applicable law, by using the Website or the Services, or by choosing to give us personal information, where your consent is required as the legal basis for us to process your personal information, you consent to the terms of this Privacy Policy and the processing of your personal information as described herein. We will otherwise process your personal information as permitted or required in accordance with applicable law.

If you do not agree with any of the terms of this Privacy Policy, please exercise the choices we describe in this Privacy Policy, or do not use the Services and do not give us any personal information.

Tree of Life may change this Privacy Policy from time to time by updating this page. You should check this page from time to time. Your continued access to and/or use of the Website or the Services after any such changes constitutes your acceptance of, and agreement to the terms of this Privacy Policy, as revised.

If you are a resident of California, please see the California addendum attached to the end of this Privacy Policy for additional information (the “California Addendum”). The California Addendum will apply if there is any conflict between the terms in this Privacy Policy and the terms of the California Addendum with respect to personal data that is subject to the laws of California.

Index

Index

This Privacy Policy contains the following sections. Please “click” to go to the information you are looking for:

  1. What Personal Information We Collect
  2. What We Do with the Personal Information We Collect
  3. When We Disclose Personal Information
  4. How We Use Cookies and Collect Information Using Technology
  5. Security
  6. Retention of Personal Information
  7. We May Transfer Personal Information to Other Jurisdictions
  8. Links to Other Websites
  9. Your Choices – Direct Marketing
  10. Your Rights
  11. Children
  12. Contact Us

1. What Personal Information we collect

The personal information we may collect depends on how you choose to use our Services. We may collect personal information when you fill out and submit forms (including, without limitation, event registration forms), use interactive features on the Website, or otherwise engage with us.

For example, when you join our mailing list, complete a form to explore the opportunity to become a retailer of our products, or attend an event that we host or participate in, we collect information such as:

  • your name;
  • your contact information, such as your address, telephone number, and email address;
  • other information you choose to submit, for example, if you complete a survey, form, or questionnaire we provide;
  • if applicable, information representing the corporation you represent, such as its name, contact information, line of business, and product information;
  • if you are a corporate retailer or other corporate entity seeking to do business with us, and that relationship includes an extension of credit, we may request credit references to assess your ability to repay. If such a retailer has a landlord, we may also request the name of the landlord, for such purpose;
  • information regarding the owners, partners, or principals of such companies, including, without limitation, their names, addresses, and phone numbers; and
  • details of your dietary requirements for catering purposes, where you attend an event organized by us.

2. What we do with the Personal Information we collect

We use the information we collect to provide the Services, to understand your needs, to provide you with better service, and, in particular, for the following reasons:

  • to allow you to apply to become a distributor of our products, or to be a supplier of product to us, and to evaluate your suitability for such, and, if applicable, to assess your ability to repay amounts owed to us. For example, we seek to understand the history of the establishment and historic sales of potential distributors and suppliers;
  • to facilitate your attendance at events that we host or participate in;
  • for our internal record keeping;
  • to improve our Services and the user experience on the Website;
  • to send emails and other communications about our products and Services, such as our newsletter, special offers, and/or other information which we think you may find interesting;
  • to manage, administer, maintain, service, collect, and enforce any agreement we have with you;
  • to respond to your questions or complaints;
  • to investigate and settle any dispute or claim which relates to the Website, products, or Services, and/or any agreement we have with you;
  • to investigate security breaches or cooperate with government authorities pursuant to a legal matter; and/or
  • for such other purposes, as are disclosed to you and to which you consent.

We may also anonymize, aggregate or otherwise strip any personal information or other information we collect of all personally identifying characteristics and may use or share such aggregated, anonymized data with third parties as permitted by applicable law.

As required by applicable law, we collect and process information about individuals in the European Economic Area and the United Kingdom only where we have a legal basis for doing so. Our lawful basis depends on the Services you use and how you interact with us. We process your information where:

  • express consent is required for processing and you have given your consent for one or more specific purposes;
  • the provision of personal information is necessary for the performance of an agreement with you, or in order to take steps at your request prior to entering into an agreement;
  • such processing is necessary for compliance with a legal obligation to which we are subject;
  • such processing is related to a task that is carried out in the public interest or in the exercise of official authority; and
  • such processing is necessary for the purposes of the legitimate interests pursued by us or a third party, without causing an undue risk of harm to anyone.

If you choose to withdraw consent from a processing of personal information we need to provide the Services, we may no longer be able to provide those Services to you.

Where we rely on the legitimate interests as a lawful basis, our legitimate interests are to be able to provide the Services to you and carry on our business activities.

3. When we Disclose Personal Information

We may share personal information with third parties that help us use your personal information for the purposes described in this Privacy Policy, including, without limitation, service providers that assist us with running the Website and/or delivering our products.

To the extent permitted by applicable law, we may transfer any personal information we have in the event of bankruptcy, or if we or any part of our business merges with or is acquired by a third party, or if any such transaction is proposed.

To the extent permitted by applicable law, we may also disclose personal information to third parties if we have reason to believe that disclosing such information is necessary to: (a) conduct investigations of possible breaches of law; (b) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; or (c) to protect our rights, safety or property, or those of others.

Finally, as permitted or required by applicable law, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

4. How we use cookies and collect information using technology

A cookie is a small file which is placed on your computer or mobile device’s hard drive. Cookies and other technologies can help analyze web traffic or let us know what portions of the Website people visit and what features they use. We may use cookies and other technologies to collect information that helps us operate and understand the use of the Website, such as, your Internet Protocol (“IP”) address or device ID, operating system, browser type, username, the pages of the Website that you visit, the time spent on those pages, access dates and times, clicks, links used, and actions you take on the Website, any errors you encounter, and general location derived from IP address.

We use cookies and other technologies to identify which portions of our Services are being used and how they are being used. This helps us analyse data about traffic on the Website, correct any errors our users encounter, and improve our Services in order to better tailor them to user needs. We also use this information for statistical analysis purposes.

We may work with third parties to collect this information. For example, we use Google Analytics, which is a web analytics service that provides statistics and basic analytical tools for website and search engine optimization. We use Google Analytics on the Website to analyze how users use and arrive at the Website. Google Analytics may collect information such as user location as inferred from IP address, the amount of time a visitor spends on the Website, which pages are more frequently accessed, how the Website is accessed (either directly, a search engine, or from a link), what sort of software is used (e.g., operating system, browser type, etc.), as well as demographics. For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners/. For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.

You can also choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Services.

5. Security

In order to help prevent unauthorised access or disclosure of personal information, we have put in place reasonable physical, electronic and managerial procedures appropriate to the nature of the information to help safeguard and secure the personal information we collect.

Personal information may be accessed by persons within our organization and our third party service providers, who require such access to carry out the purposes described in this Privacy Policy, or otherwise permitted or required by applicable law.

our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

6. Retention of Personal Information

Pursuant to applicable law, different retention periods may apply for different types of personal information. In most cases, we use the purpose the personal information was collected for to determine the length of time that we retain it. In some instances, such as when required by law, we may retain the information for a longer period.  Other criteria considered in the length of retention include, without limitation, the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, and third party requirements on retention.

7. We may Transfer Personal Information to Other Countries

Personal information that we collect may be stored and processed in Canada and outside your jurisdiction of residence, in any other country in which we or our service providers maintain facilities, including, without limitation, the United States. Personal information processed and stored in another jurisdiction may be subject to disclosure or access requests by the governments, courts, or law enforcement or regulatory agencies in that jurisdiction according to its laws.

By using our Services or by providing us with personal information, you consent to any such transfer of information outside of your jurisdiction. If you have any questions about our use of service providers outside of your jurisdiction, you may contact us using the information below.

8. Links to other websites

Our Services may contain links to other websites that may interest you. However, once you have used these links to leave the Website, you should note that we do not have any control over that other website. We cannot be responsible for the protection and privacy of any information which you provide when visiting such sites, and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to any website you visit.

9. Your Choices

Depending on your jurisdiction and the lawful basis for processing, you may choose to restrict the collection or use of your personal information in the following ways:

  • you may write to or email us using the contact information below to require us to stop using your personal information for direct marketing purposes; and/or
  • if you receive a commercial email from us, you can unsubscribe using the unsubscribe tool we provide in such messages.

If you choose to withdraw consent from a processing of personal information that we need to provide the Services, we may no longer be able to provide such Services to you.

10. Accessing and Correcting your Personal Information, Your Rights

You may request access to your personal information that we hold, including, without limitation, to request a correction to it if you believe it is inaccurate, subject to exceptions in applicable law. If you would like to have access to the personal information we have about you, or if you would like to have it corrected, please contact us using the contact information provided below (or, for California residents, using the methods in the California Addendum). In some cases, we may not be able to allow you to access certain personal information, for example, if it contains personal information of other persons or for legal reasons.

Under certain circumstances and subject to applicable data protection laws, you may also be entitled to request additional information regarding our personal information governance practices, including, without limitation, details regarding what personal information is collected about you, the categories of persons who have access to your information, and how long your information will be retained for. You may also be entitled to request that we cease communicating your information, or de-index any hyperlink material attached to your name that provides access to your personal information by a technological means.

Depending on your jurisdiction of residence, you may have additional rights under applicable law, including, without limitation, the right to opt out of any sales or sharing of your personal information, to request access to and information about our data practices, to restrict the processing of your personal information, to opt out of the processing of your personal information, to receive copies of your personal information and have it transferred to another controller, to have your personal information deleted or otherwise removed, as well as the right not to be discriminated against for exercising your privacy rights. Where processing is based on your consent, you have the right to withdraw that consent at any time, however that does not affect the lawfulness of processing based on the consent provided before its withdrawal.

If you have a complaint about how your personal information is being maintained, or if you have questions regarding how to exercise your rights, or if you wish to submit a request, please contact us using the contact information provided below. You may also lodge a complaint with a competent regulator in your jurisdiction of residence, or the jurisdictions where we are located.

To help protect against fraudulent requests related to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your personal information.

11. Children

We do not intend to collect information from children. If you are under the age of sixteen (16) or, if greater, the majority where you reside, please do not provide us with any personal information.

12. Contact Us

If you have any questions regarding this Privacy Policy, any personal information you have submitted to us, or if you would like to:

  • exercise your rights with respect to your personal information; or
  • to submit a complaint,

please advise us by contacting our Privacy Officer by writing to: mario.delgadinho@treeoflife.com. You may also email us at info@treeoflife.com. If you are resident of California, please see the California Addendum.

TREE OF LIFE CANADA, ULC
ADDENDUM TO THE PRIVACY POLICY

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Introduction

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Tree of Life Canada, ULC Privacy Policy to which this Privacy Notice is attached (the “Privacy Policy”) and applies solely to all visitors, users, and others who are residents of the State of California (“consumers” or “you”). Any terms used but not otherwise defined herein will have the meanings set out in the Privacy Policy.

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended and expended by the California Privacy Rights Act of 2020 (“CPRA”), and any terms defined in the CPRA have the same meaning when used in this Privacy Notice.

Information We Collect

We have collected the categories of personal information from consumers who are California residents within the last twelve (12) months as designated below:

Category

Examples

Collected

A.

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers

YES

B.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Name, address, telephone number, employment, employment history. Some personal information included in this category may overlap with other categories

YES

C.

Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, immigration and citizenship status, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)

YES, as to medical condition – specifically allergies if disclosed) 

NO as to other data

D.

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

NO

E.

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data

NO

F.

Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement

YES

G.

Geolocation data

Physical location or movements

YES, the Website uses Google Analytics which collects the Website visitor’s geolocation data

H.

Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information

NO

I.

Professional or employment-related information

Current or past job history or performance evaluations

YES (current job)

J.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records

NO

K.

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

NO

L.

Sensitive personal information

A Social Security number, driver’s license number, state identification card number, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, the contents of mail, email and text messages unless the business is the intended recipient of the communication, genetic data, biometric and health information, information regarding sex life or sexual orientation,  neural data (information that is generated by measuring the activity of a consumer’s central or peripheral nervous system, and that is not inferred from nonneural information)

YES, only medical information (allergies) if disclosed by event attendee

Use of Personal Information

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

  • to fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
  • to register you at your request for attendance at one of our trade shows or other events, and to determine your food preferences or food allergies for purposes of planning meals at our events that you will attend.
  • to send you non-marketing commercial communications.
  • to send you email notifications that you have specifically requested.
  • to send you marketing communications relating to our business, where you have specifically agreed to this, by email or similar technology.
  • to provide, support, personalize, and develop our Website and Services.
  • to 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 based on your use of the Website
  • to help maintain the safety, security, and integrity of the Website, databases and other technology assets, and business.
  • to respond to law enforcement requests and as required by applicable law, court orders, or governmental regulations.
  • to the extent that we are required to do so by law.
  • in connection with any ongoing or prospective legal proceeding.
  • as described to you when collecting your personal information.
  • 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’s users is among the assets transferred.
  • to perform services on behalf of your employer, including, without limitation, maintaining or servicing your employer’s accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services.

Tree of Life will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Use and Disclosure of Sensitive Personal Information

Tree of Life does not use or disclose sensitive personal information collected on the Website for any purpose other than trying to provide food at trade shows and other events that you attend that meet your preference if we are able. 

Disclosure of Personal Information

We may disclose your personal information to our service providers or contractors with whom we have a contract to process your personal information for a specific business purpose, such as to our event management company to ensure that you are registered for our trade show and are properly checked in. We may also disclose information regarding your use of the Website to our service providers to help us protect or improve the Website. When we disclose personal information to a service provider or a contractor, we enter a contract with them that requires them to use the information only for that business purpose and prohibits them from taking certain actions with your information, such as selling your information and sharing it with others for cross-context behavioral advertising.  

Tree of Life does not knowingly disclose your personal information with other third parties.  

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have has disclosed the following categories of personal information for a business purpose. These categories are more fully described in the “Information We Collect” section above:

  • Category A: Identifiers
  • Category F: Internet or other similar network activity
  • Category I: Employment History
  • Category L: Sensitive Personal Information

Retention of Personal Information

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Notice. We delete your food preference and allergy information within thirty (30) days after the applicable trade show or event is over. For other personal information, different retention periods apply, and in most cases, we use the purpose for which we collected the personal information to determine the length of time that we need to retain it. In some instances, such as when required by law, we may retain the information for a longer period.

Sales or Sharing of Personal Information

In the preceding twelve (12) months, we have not sold or shared personal information, as defined by the CPRA.

Your Rights and Choices

California law provides consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Tree of Life disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see the “Exercising Access, Data Portability, Deletion, and Correction Rights” section below), we will disclose to you:

  • the categories of personal information we collected about you, including sensitive personal information.
  • the categories of sources for the personal information we collected about you.
  • our business or commercial purpose for collecting, selling, or sharing that personal information.
  • the categories of third parties with whom we share that personal information.
  • the specific pieces of personal information we collected about you.
  • in connection with any personal information we may sell, share, or disclose to a third party for a business purpose:
    • the categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared, if any; and
    • the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

Deletion Request Rights

You have the right to request that Tree of Life delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see the “Exercising Access, Data Portability, and Deletion Rights” section below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s).

Right to Correction

You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt and confirmation of a verifiable consumer request from you (see the “Exercising Access, Data Portability, and Deletion Rights” section below), we will use commercially reasonable efforts to correct the inaccurate personal information.

Exercising Access and Data Portability, Deletion, and Correction Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us, toll-free, at [insert phone number]; or

Emailing us at [insert email address].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

Your authorized agent may submit a request by calling [insert phone number]. To protect the privacy and security of your data, we may contact you or your authorized agent to collect additional data to verify your identity, your agent’s authorization, and to verify the request.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or an individual for whom you are an authorized representative.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt, unless otherwise required by applicable law. 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 useable and should allow you to transmit the information from one entity to another without hindrance.

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.

Protection Against Discrimination

You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA and CPRA.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Website that are consumers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to: info@treeoflife.com.

Do Not Track

Tree of Life does not knowingly track visitors to the Website over time and across third party sites. Web browsers or other mechanisms may give users options regarding the collection of information about their online activities over time and across third party sites and online services. At this time, we do not respond to browser “Do Not Track” signals.

Please be aware that we do not control the tracking of third party websites or services to which you may link from the Website. 

If you would like additional information about online tracking and various opt-out mechanisms, please see https://allaboutdnt.com/

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Tree of Life collects and uses your information described above, and in the Privacy Policy, for your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at the email address set forth in the Privacy Policy.

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