Privacy Policy

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Nutritional High International Inc.

Privacy Policy

Last updated May 7, 2018

Welcome to www.milehighfliclub.com (the “Site“), provided by Nutritional High International Inc. and its affiliated entities which may be directly or indirectly owned by Nutritional High International, Inc. own or administer the actual websites, programs or mobile applications and related services (“NH“, “our“, “we” and “us“).  This privacy policy (“Privacy Policy“) describes the information we gather from you when you use the Site, mobile applications, and related services (together, the “Services“) and our policies and how we collect, use, and disclose that information.  By using the Site, you agree to this Privacy Policy. By submitting your personal information through our Services, you consent to the transfer and storage of your personal information to our servers and third party service providers in Canada, in the United States of America, and in such other countries as we may decide from time to time and the collection use, and disclosure of information about you as described in this Privacy Policy.

This Privacy Policy is a legally binding contract between NH, on the one hand, and you and your successors and heirs, and (if applicable) the corporate entity that you represent (in this Privacy Policy, you shall be referred to as “you” or “your”), on the other hand. By accessing or using the Sites or Services, you are agreeing to be legally bound by this Privacy Policy. If you do not accept and agree to this Privacy Policy, you may not access or use any of the Sites or Services or create an account or user profile.

  1. Privacy Rights and Accountability

 

NH is obliged to comply with the privacy laws of all of the jurisdictions in which it carries on business which, in Ontario, includes Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA“). PIPEDA gives you rights concerning the privacy of your personal information.  NH is responsible for the personal information it collects and holds. To ensure this accountability, NH has developed this Privacy Policy and has trained its staff in respect of it.

 

  1. Information We Collect and How We Collect It

 

When you create an account and use our Services, NH collects the following types of information from you:

 

  1. your name;
  2. your contact information, such as your email address and phone number;
  3. your demographics information, such as your gender;
  4. your geographic location;  and
  5. any other information you provide to us, such as reviews, content, and your biography.

 

If you create an account using, or otherwise connect your account to, a social networking services account (such as Twitter or Facebook), NH may also collect information provided to us by such social networking services including for example your name, email address, birthday, geographic location, interests, profile picture, gender, networks, user ID, list of friends, and any information you have made public on such social networking account.

NH automatically collects information about how you use our services – for example, pages you have viewed. NH also collects certain technical information about your computer or mobile device including your Internet protocol address, geo-location information, your browser type, language and identifying information, your operating system and application version, device type, device model and manufacturer, device identifiers, and your device operating system type and version.

NH also uses cookies, Web beacons, and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. NH may use both session cookies (which expire once you close your web browser) and persistent cookies (which usually stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Web beacons are digital images that are used to log information on the Services or in our emails. NH uses web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use web beacons to tell if you open or act on our emails. You can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising. The opt-out is http://www.milehighfliclub.com/unsubscribe.

Others, including third party analytics service providers and advertising partners may also collect personal information about your online activities over time and across different websites when you use our Services, including as described in this Privacy Policy. This Privacy Policy does not apply to and we are not responsible for those other parties. Third party analytics services may use cookies and web beacons through our Site (for example, Google Analytics) and platform device identifiers and software agents on and through our Services to provide us with information about how you use and interact with our Site. We encourage you to review the privacy policies of these third parties to learn about your choices about information they collect from you.

  1. Sharing Of Your Information

 

The Services may allow you to connect and share your actions, comments, content, profile, and information publicly or with other people. You may control some of the categories of personal information shared via your profile from the account settings menu on the Site. Please be mindful of your own privacy needs as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.

 

The Services may also provide you with the option to share certain information from your NH account with social networking services like Facebook and Twitter. We are not responsible for the use or re-sharing by others of any of your information once it is made public. If you do not want your information to be made public, you should not use the Services in this manner and/or you should adjust your privacy settings on the applicable social networking service accordingly. NH is not responsible for and NH does not control these social networking services privacy practices. Please review the applicable privacy policy for information about how they use your information.

  1. How NH Uses Your Information

 

NH generally uses your information to:

 

  1. facilitate the creation of and secure your account for the Services;
  2. identify you as a user in our system;
  3. provide, personalize, and improve the Services;
  4. communicate with you about your use of the Services;
  5. develop new products and services,
  6. customize the advertising you view and recommend content;
  7. fulfill your requests;
  8. send newsletters, surveys, offers and promotional materials related to the Services and for other marketing purposes of NH using your contact information;
  9. protect, investigate, and prevent potentially fraudulent, unauthorized, or illegal activities;
  10. protect NH’s rights and the rights of other users; and
  11. do such other things as are described in this Privacy Policy.

 

We may also use your information to verify your geographic location. We may use your geographic location data to personalize our Services, to recommend content, determine whether the information you have requested is available in your location.

  1. How NH Discloses Your Information

 

We may share your information as follows:

 

  1. with your consent or at your direction;
  2. with others who perform services on our behalf;
  3. if we are required to do so by law, or to comply with a court order, judicial or other government subpoena, or warrant;
  4. if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses or to protect NH and our Services, or any rights, property, or personal safety of NH or others;  and
  5. if NH is or may be acquired by or merged with another company or involved in any other business deal (or negotiation of a business deal) involving sale or transfer of all of our business or assets.

 

NH may also share aggregated and anonymized data with our partners, advertisers, and other third parties.

When NH transfers your personal information to a third party to provide administrative and other services, it uses appropriate measures to ensure that the third party will use your personal information only to perform the services NH has specified. Sometimes NH may use administrative service providers who may not be located in either Canada or the United States of America. Accordingly, your personal information may be transferred outside of North America and if so, it will be subject to the legal requirements of the applicable foreign jurisdictions, including local requirements to disclose information to courts, law enforcement and national security authorities.

To the extent NH enters into arrangements with service providers, agents and contractors to store, handle or process personal information on its behalf, such as for data processing, document storage software support and office services, NH’s will require such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them.

 

  1. Third Party Advertisers

 

NH permits advertisements to be delivered to you by third party Internet advertising companies (also called ad networks or network advertisers). These companies may use cookies, web beacons, platform device identifiers, software agents, and other technologies to collect non-personal information about your visits over time on our Services and across other websites to deliver advertisements to you targeted to your interests, measure their effectiveness and personalize advertising content, and to understand the usage and visitation of the Services and the other applications and websites tracked by these advertising companies. NH does not have access to or control over cookies, web beacons, platform device identifiers, software agents, or other technologies that they may use. NH is not responsible for the privacy practices of third party advertisers. NH does not share your personal data with any third-party advertisers or ad networks for their advertising without your permission except for: (i) hashed or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., lead generation form) or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an ad on or off the Site or an NH app, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. You should check the privacy policy of the third party advertiser to determine how it handles information it separately collects from you.   We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads. For Visitors, the setting is http://www.milehighfliclub.com/unsubscribe.

 

  1. Security

 

NH takes commercially reasonable steps to help protect your personal information against loss, misuse and unauthorized access, or disclosure. NH uses standard safeguards to protect the security of personal information in its possession including physical, organizational and technological measures. These measures include:

 

  • premises security;
  • restricted access to files that contain personal information;
  • technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access; and
  • internal password and security policies.

No method of transmitting or storing information is completely secure, and no company can fully prevent security risks, however. While NH strives to protect your personal information, NH cannot guarantee its absolute security. To help protect yourself and your information, choose a unique password for our Services and do not use a password on our Services that you would use on any other website or online service. NH cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be virus free. NH makes no warranty with respect to the integrity of any electronic communications between NH and you or with respect to the security of any such communication and you consent to NH’s exchange of electronic communications unencrypted.

  1. Serious Privacy Breach Notifications

 

NH will notify you of any breach of the security safeguards involving your personal information under NH’s control (“Privacy Breach“).  This notice will be conspicuous and given to you in the manner prescribed under the applicable law which may include, but are not limited to, any requirements of PIPEDA as soon as feasible after NH determines that such a breach has occurred.

 

Likewise, NH will report any Privacy Breach to the applicable privacy authority including the Office of the Privacy Commissioner of Canada in the manner prescribed under PIPEDA as soon as feasible after NH determines that such a breach has occurred.  

  1. Legal Disclosures

 

It is possible that NH will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of NH, personnel, or others. NH will attempt to notify you about legal demands for your personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. NH may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but NH does not promise to challenge every demand.

 

  1. Information Choices

 

You may opt out of receiving promotional emails from NH by following the instructions in those emails or by reviewing the settings in your account. If you opt out, NH may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your personal information, including changes to your contact preferences, changes to or deletions of your information or content you post, and requests to opt-out of sharing your personal information with third parties by emailing fli@milehighfliclub.com. Please note that deletion of your information or content does not ensure complete or comprehensive removal of the content or information posted on the Services.

 

  1. Rights to Access and Control Your Personal Information

 

NH provides many choices about the collection, use and sharing of your information, from deleting or correcting information you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. NH offers you settings to control and manage the personal data we have about you.

 

For personal information that we have about you:

  • delete information: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you);
  • change or correct information: You can edit some of your personal information through your account. You can also ask us to change, update or fix your information in certain cases, particularly if it is inaccurate;
  • object to, or limit or restrict, use of information: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal information is inaccurate or unlawfully held);  and
  • right to access and/or take your information: You can ask us for a copy of your personal information and can ask for a copy of personal information you provided in machine readable form.

 

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

 

You may have the right to know what personal information NH has about you and to correct any inaccuracies. You may ask for access to any personal information NH holds about you. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to fees. Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons. Please direct any such requests to our Privacy Officer as set forth below in Section 13.

 

12. California Residents: Your California Privacy Rights

California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at the email set forth below in Section 13. Please allow up to thirty (30) days for a response.

 

  1. How to Contact Us and the Privacy Commissioner of Canada

 

If you have any questions or comments about this Privacy Policy, your personal information, our third-party disclosure practices, or your consent choices, please contact NH through our Privacy Officer at the following address:

 

Nutritional High International Inc.
Attention: Privacy Officer
77 King Street West, Suite 2905
P.O. Box 121 Toronto
ON M5K 1H1
Telephone: 647-985-6727
Fax: 888-262-4724
Email: fli@milehighfliclub.com

If you are not satisfied with any of our responses to your privacy questions, the Privacy Commissioner of Canada can be reached at:

112 Kent Street

Place du Ville Tower, 3rd Floor

Ottawa, Ontario  K1A 1H3

1.800.282.1376

 

  1. Changes to this Privacy Policy

 

NH reserves the right to change this Privacy Policy from time to time. The most current version of this Privacy Policy is posted on the website. Regardless of any changes NH makes to this Privacy Policy, NH will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information, or as otherwise required or permitted by law, unless you have given your consent for NH to do otherwise.  If NH makes any material changes, we will notify you by sending you an e-mail communication to the last e-mail address you provided to us and by prominently posting a notice of the changes on the Site. Any changes to this Privacy Policy will be effective upon the earlier of our dispatch of an e-mail notice to you (if applicable) or our posting of notice of the changes on the Site. You are responsible for providing us with your most current e-mail address. In the event that the last e-mail address you provided to us is no longer valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If your e-mail address is not up to date or is not working, the posting of a notice of changes to this Privacy Policy on the Site shall constitute effective notice of the changes described therein. Continued use of any of the Site or Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. We may also post additional privacy policies or statements that apply to certain portions of the Site or Services, and your access to and use of such Site or Services shall be deemed to be your approval and consent to such additional privacy policies or statements.

 

15. Do Not Track

NH does track its customers over time and across third party websites to provide intelligent advertising, and does not respond to Do Not Track (“DNT”) signals. In addition, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. Please review your web browser’s internet options for more details.

16. International Data Transfer

If you are located outside of the United States, please be aware that information we collect, including, but not limited to, personal information, will be transferred to, and processed, stored and used within the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including personal information, in the United States as set forth in this Privacy Policy.

Please note that we take the privacy of our users seriously and therefore take steps to safeguard your personal information, including assuring an adequate level of data protection in accordance with international standards. If you would like additional information about your personal data and its use in connection with the Site and Services, including revising any incorrect information, please contact the Data Privacy Manager at the address in Section 13 above. We will take such steps as we deem necessary to confirm your identity before sharing any personal data with you. We will respond to proper and confirmed requests relating to personal data within thirty (30) days, or as otherwise required by applicable law. If you are not satisfied with the way your request was handled, you may refer your request to your country’s data management authority.

  1. Promotions:

 

We may sometimes offer other loyalty programs and promotions (any, a “Promotion”) through the Site or Services that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, further posting in association with the Promotion. If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with your participation and the administration of such Promotion, including, in connection with reward fulfillment, and as required by law or permitted by the Promotion’s official rules.

 

  1. Effective Date

 

This Privacy Policy was last updated and is effective as of May 7, 2018.