GREENLEAF FOODS

Privacy Statement and Cookies Policy

Greenleaf Foods, SPC, owner of the Lightlife® and Field Roast^TM brands, and its affiliates (collectively, “Greenleaf”, “we”, “us” or “our”) take steps intended to meet privacy principles and requirements with respect to personal information under applicable privacy legislation. The purpose of this statement is to inform our customers, consumers and other individuals we deal with (“you” or “your”) how we collect, use, disclose and protect your personal information. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This statement applies to our collection, use and disclosure of personal information in Canada, and other jurisdictions, subject to the EU’s General Data Protection Regulation (“GDPR”), if, and to the extent, applicable. This statement does not apply to information about current, future or former employees (see our Employee Privacy Notice) or to information that is not personal information. 

 

Personal information we collect

Greenleaf and its agents and representatives collect personal information in a number of circumstances in the course of its business. Since the information you submit to us online may not be encrypted, we cannot guarantee the absolute privacy of that information. Personal information we collect includes:

• contact information such as name, address, geo-location, email address, username that functions as online contact information, a persistent identifier, telephone number;
• information provided when you register or otherwise provide information on our website;
• information provided when you complete questionnaires or surveys;
• information provided when you participate in a promotion or contest;
• information provided otherwise such as by telephone, by mail or through our website;
• records of customer calls or product-related comments or inquiries;
• such other information we may collect with your consent or as permitted or required by law.

 

Use of personal information

Greenleaf generally uses personal information for the following purposes:

• receiving and replying to your requests, inquiries and comments;
• with your consent, sending you information about products and promotions offered by Greenleaf and/or contacting you to conduct telephone surveys and market research;
• with your consent, sending coupons from time to time;
• providing customer service;
• administering promotions and contests;
• creating a database of individuals who have registered to receive information from us;
• understanding your preferences, needs and interests and, with your consent, offering you products and information that are likely to be of interest to you and personalizing your experience when visiting our website such as by presenting you with information and offerings that we think will be of interest to you;
• improving our products;
• managing our business, including customer and consumer relations;
• ensuring the security of our business operations including our website;
• managing, administering, collecting or otherwise enforcing accounts;
• maintaining business records for reasonable periods and as required by law, and generally managing and administering our business, including defending and prosecuting legal claims;
• meeting legal, regulatory, insurance, security, accounting and processing requirements;
• purposes disclosed at the time of collection of personal information; and
• otherwise with consent or as permitted or required by law.

 

Collection of your personal information

Greenleaf collects personal information for the following commercial purposes:

1. to establish and maintain responsible commercial relations and to provide ongoing service and communication;
2. to understand customer needs, trends and preferences;
3. to evaluate, develop, enhance, market or provide Greenleaf’ products and services;
4. to run contests and programs;
5. to manage and develop Greenleaf’ business and operations;
6. to meet legal and regulatory requirements;
7. to protect Greenleaf against error and fraud;
8. for any other purpose to which an individual consents; and
9. for any other legitimate grounds for collection or use of personal information.

 

Disclosure of your personal information

Greenleaf may disclose personal information, including in the following circumstances to:

1. a person who in the reasonable judgment of Greenleaf is seeking the information as an agent;
2. a company or individual retained by Greenleaf to perform functions on its behalf, such as research or data processing;
3. a company or individual retained by an individual, who represents that it expressly is entitled to receive such individual’s personal information, or in the reasonable opinion of Greenleaf implicitly is entitled to receive such individual’s personal information;
4. a company or individual retained by Greenleaf for the evaluation, development, enhancement, marketing or provision of any of Greenleaf’ products or services;
5. an agent utilized by Greenleaf to evaluate the customer’s creditworthiness or to collect the customer’s account;
6. a credit reporting agency;
7. a public authority or agent of a public authority, if in the reasonable judgment of Greenleaf, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information;
8. a third party or parties, where the customer consents to such disclosure or disclosure is required by law;
9. a financial institution on a confidential basis and solely in connection with the assignment of its right to receive payment, the provision of security or other financing arrangements; and
10. professional advisors, consultants, investigators and adjudicators in defending and prosecuting legal claims.

 

Greenleaf may disclose personal information to affiliates and business partners in order to permit them to send you occasional information about their products and services in accordance with your consent.

In addition to the above, personal information may be disclosed to our affiliates in other jurisdictions for internal audit, management, billing, administrative and other general business purposes.

Service Providers
Greenleaf may transfer personal information to outside agents or service providers (including affiliates of Greenleaf acting in this capacity) that perform services on our behalf, for example data processing services such as mailing, call center, billing, marketing, information technology or data hosting or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes and uses described in this Privacy Statement. Some of these service providers or affiliates may be located in other jurisdictions, and your personal information may be collected, used, disclosed, stored and processed in such jurisdictions for the purposes and uses described in this Privacy Statement. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to legal requirements in the applicable jurisdiction. For example, we may be required due to lawful requirements to disclose personal information to government authorities in those countries.

Business Transactions
Personal information may be used by Greenleaf and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of Greenleaf or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples:

• permitting those parties to determine whether to proceed or continue with the transaction
• fulfilling reporting, inspection or audit requirements or obligations to those parties. Assignees or successors of Greenleaf or our business or assets may use and disclose your personal information for similar purposes and uses as those described in this Privacy Statement.

 

We do not sell your personal information.

 

Legal, Regulatory, etc.
Greenleaf may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to Greenleaf or our agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).

Cookies policy and our website

Information Collection

Active Information Collection: Greenleaf’s actively collects information from its visitors both by asking you specific questions and by permitting you to communicate directly with us via email and/or feedback forms. Some of the information that you submit on the website may be personal information. Collection, use and disclosure of information actively collected from you have been described.

Passive Information Collection: As you navigate through Greenleaf’s website, certain anonymous information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the website some of this anonymous information, such as the URL of the website you just came from, the Internet Protocol (IP) address, time of visit, date of visit, the pages visited within the Site, and the browser version your computer is currently using. Greenleaf’ website may also collect anonymous information from your computer through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of the website might not work without cookies. By using our website you are considered to consent to the use of cookies and other passive information collection.

The Greenleaf website may use and combine such passively collected anonymous information to provide better service to Site visitors, customize the Site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the Site for your use. Such passively collected anonymous information is not combined with personal information collected elsewhere on the website, unless you have consented to have your personal information collected in conjunction with this passive information.

Cookies
We use cookies on our website to improve its performance and enhance your user experience. By accessing our website, you agree that this Cookies Policy will apply whenever you access our website.

The cookies that may be used by Greenleaf can be categorized in the table below. It is important to note that not all cookies may be used in all jurisdictions or on all websites.

Category	Description
Strictly Necessary cookies	These cookies are essential in order to enable you to move around the site and use its features, such as accessing secure areas of the site. Without these cookies, services you have asked for cannot be provided.
First party analytics cookies	These cookies allow us to employ data analytics so we can measure and improve the performance of our site and provide more relevant content to you. These cookies don’t collect information that identifies a visitor down to an individual level that is available to us. These cookies are not passing personally identifiable information to any external third party other than in limited cases when we engage a service provider to act on our behalf but who is then unable to use the data for their own purposes (eg. Google Analytics).
Performance cookies	Performance cookies are generally third-party cookies from vendors we work with or who work on our behalf that collect information about your visit and use of the Greenleaf website, for instance which pages you visit the most often, and if you get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how the website works. Third party vendors may have access to this data and may use it to improve their overall services and offerings.
Functionality cookies	These cookies allow a site to remember choices you make (such as your username, language or the region you are in) and provide more enhanced, personal features. These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the Internet outside our site.
Advertising and social media cookies	Advertising and social media cookies (including web beacons and other tracking and storage technologies) are used to (1) deliver advertisements more relevant to you and your interests; (2) limit the number of times you see an advertisement; (3) help measure the effectiveness of the advertising campaign; (4) retargeting to Greenleaf websites/information and (5) understand people’s behavior after they view an advertisement. They are usually placed on behalf of advertising networks with the site operator’s permission. They remember that you have visited a site and quite often they will be linked to site functionality provided by the other organization. This may impact the content and messages you see on other websites you visit.

 

Greenleaf reserves the right to amend cookies used in conjunction with its website and you are encouraged to review this Privacy Statement and Cookies Policy for periodic updates describing any changes to cookies used.

Do not track mechanisms

Because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals.

 

Your consent

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide personal information necessary for a service you have requested or the purpose is obvious). You may be asked to provide your specific consent in some special and specific circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt-out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, you are deemed to consent to our collection, use and disclosure of such personal information for the purposes and uses identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection. For residents of the EU, subject to the GDPR, consent will be express if personal information is collected for purposes and uses other than as set out in this Privacy Statement.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Note also that where we have provided or are providing products or services to you, your consent will be valid for so long as necessary to fulfill the purposes and uses described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to Canadian and foreign government entities as required to comply with laws, and reporting on credit information after credit has been granted, if applicable).

Greenleaf collects, uses and discloses your personal information with your consent, except as permitted or required by law. Accordingly, notwithstanding the foregoing, we may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent – for example, to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

Email marketing

We may provide you with an opportunity to “opt in” to receive additional email communication from us.  If we offer an “opt-in” mechanism for such communication pursuant to which you expressly choose to receive it, we also offer you an “opt-out” mechanism to provide you the opportunity to indicate that you do not want us to send you such further communications.     

About children and teenagers

We do not intend to collect personal information from individuals under the age of 13 without parental consent and take active steps to comply with applicable laws, including the Children’s Online Privacy Protection Act (COPPA). We may, from time to time, offer a contest where children under the age of 13 can enter in which case the personal information is used for purposes of administering the contest and determining a winner.  In these cases, we instruct the participant to provide the email address of their parent or guardian.  When a participant under the age of 18 is selected as a prize-winner in a contest or sweepstakes, an e-mail is sent to the parent or guardian. This e-mail contains a form that requests the participant’s real name and address and a parental permission form. For the participant to receive the prize, the parent or guardian must complete and submit the permission form. We do not sell the personal information.

If a child under 13 has provided us with personal information without parental consent, we ask that a parent or guardian of the child contact us to request that this personal information be deleted from our records. We will use reasonable efforts to delete the child’s personal information from our existing files.   We will also use reasonable efforts to delete all contact and other personal information obtained from a teenager (under the age of 18)  if a parent or guardian notifies us that they wish to withdraw consent for the collection of a teenager’s personal information.

We encourage parents to talk to their children about their use of the Internet and the personal information they disclose to websites or otherwise.

Security

We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the personal information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and mandataries of Greenleaf who require access to your personal information in order to fulfil their job requirements will have access to your personal information.

Access, correction and contacting us

Greenleaf may establish and maintain a file of your personal information for the purposes described above, which will be accessible at P.O. Box 61016 Winnipeg, MB, R3M 3X8, Canada. If you wish to request access or correction of your personal information in our custody or control, you may write to the above address, attention Consumer Affairs. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. If you wish to make inquiries or complaints or have other concerns about our personal information practices, contact us at info@greenleaffoods.com.

 

Links to other websites and social media

This website may contain links or references to websites to which this Privacy Statement and Cookies Policy does not apply. Greenleaf is not responsible for the data collection and use practices of companies or organizations to which this website may provide links.

Social media platforms provide tools that many of our customers and consumers use and enjoy, and we include links to various social media platforms on our Website. If you interact with these social media platforms through our Website, your experience on those platforms will be governed by the privacy and other policies of those platforms. We encourage you to choose your privacy settings on those sites accordingly.

Changes to the Privacy Statement and Cookies Policy

This Privacy Statement and the Cookies Policy may be revised from time to time. If we intend to use or disclose personal information for purposes and uses materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us as described above or check our website periodically at www.mapleleaffoods.com to obtain a current copy of the Privacy Statement and Cookies Policy.   Your continued provision of personal information or use of our services following any changes to this Privacy Statement and the Cookies Policy constitutes your acceptance of any such changes. This Privacy Statement and the Cookies Policy is effective as of March 2022.

 

 

 

ADDENDUM:  California Privacy Rights

Applicability

This section applies only to California consumers. For purposes of this section “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers’ Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Information. Greenleaf is a business, and does not sell Personal Information. We may share Personal Information with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.

How We Collect, Use, and Share your Personal Information

We have collected the following statutory categories of Personal Information in the past twelve (12) months:

• Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.
• Commercial information, such as subscription records. We collect this information directly from you.
• Internet or network information, such as browsing and search history. We collect this information directly from your device.
• Geolocation data, such as IP address. We collect this information from your device.
• Other Personal Information, in instances when you interact with us online, by phone or mail in the context of customer or consumer inquiries, complaints or questions, and participation in customer surveys or contests.

The business and commercial purposes for which we collect this information are described above in the Privacy Statement under the headings “Use of Personal Information” and Collection of Your Personal Information”. The categories of third parties to whom we “disclose” this information for a business purpose are described above in the Privacy Statement under the heading “Disclosure of Your Personal Information.

Your California Rights

You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law. 

The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.

The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.

The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

Greenleaf does not sell Personal Information to third parties

How to Exercise your California Rights

You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your Personal Information.

Please contact info@greenleaffoods.com, if you would like to:

• Access this policy in an alternative format;
• Exercise your rights;
• Learn more about your rights or our privacy practices; or
• Designate an authorized agent to make a request on your behalf.