PRIVACY POLICY
THE NAKA APP
Introduction
Naka Healthy Foods Inc. and our affiliates and subsidiaries (“Company” or “we”) respect your privacy and are committed to protecting it by complying with this policy in the provision of the Naka App, our online App-based platform for the purchase of fresh foods (the “App”). For more information on the App, see the website https://www.nakahealthyfoods.ca.
Canadian privacy laws generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
Following on this definition, this privacy policy (“policy”) describes:
- how we collect, use, disclose, and protect the personal information of App users (“you”);
- the types of information we may collect from you or that you may provide when you use or visit the App; and
- our practices for collecting, storing, using, maintaining, protecting, and disclosing that information.
This policy applies to personal information we collect, use, or disclose about you:
- on the App;
- in email, text, and other electronic messages between you and the App; and
- when you interact with any advertising and applications on third-party applications and services that we may adopt from time to time, if those applications or advertising include links to this policy.
We will only collect, use or share your personal information in accordance with our Terms of Use and this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for specific and limited purposes.
This policy DOES NOT apply to information:
- that we collect offline or through any other means, including on any other Company or third-party application (including our affiliates and subsidiaries); or
- that you provide to or is collected by any third party (including our affiliates and subsidiaries), through any application, website, or content (including advertising) that may link to or be accessible from or on the App.
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our App. By accessing or using this App, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to This Policy). Your continued use of this App after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.
The App may include links to third-party applications, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-parties, and we encourage you to read the privacy policy of every website or application you visit.
What Information Do We Collect?
We may, but do not necessarily, collect and use several types of information from and about you, including:
- personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, payment, billing and account information, social insurance number, and any other identifier we may use to contact you;
- non-personal information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific App feature;
- technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our App, and usage details; and
- non-personal details about your App interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our App (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
How We Collect Personal Information
We may, but do not necessarily, use different methods to collect your information, including through:
- direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise;
- automated technologies or interactions, as you navigate through our App. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies;
- automated location tracking features that identify your geographic location; or
- third parties or publicly available sources, for example, our business partners.
Information You Provide to Us
The information we collect directly from you on or through our App may include:
- information that you provide by filling in forms on our App. This includes information provided at the time of registering to use our App, subscribing to our service, posting material, and or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our App;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to surveys that we might ask you to complete for research purposes;
- details of transactions you carry out through our App and of the fulfillment of your food purchases. You will be required to provide financial information before placing an order through our App; or
- your search queries on the App.
Information regarding payment for food purchases from Stores is shared directly and securely with a third-party payment platform, Stripe.
Information We Collect Through Cookies / Other Automatic Collection Technologies
As you navigate through and interact with our App, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- details of your visits to our App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the App; and
- information about your mobile device and internet connection, including your IP address, device operating system, and (if applicable) browser type.
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this App and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statistical data and may include personal information, and we may maintain it or associate it with personal information we collect in other ways that you provide to us, or receive from third parties. It helps us to improve our App and to deliver a better and more personalized service, including by enabling us to:
- estimate our market size and usage patterns;
- store information about your preferences, allowing us to customize our App according to your individual interests;
- speed up your searches; and
- recognize you when you return to our App.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A “cookie” is a small file placed on the hard drive of your computer by a website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our App. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our App.
- Flash Cookies. Certain features of our App may use local stored objects (or “Flash Cookies”) to collect and store information about your preferences and navigation to, from, and on our App. Flash Cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash Cookies, see Choices About How We Use and Share Your Information.
- Web Beacons. Pages of our App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on the App, including advertisements, may be, but are not necessarily, served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our App so that you can enjoy free content.
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Share Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- to present our App and its contents to you;
- to facilitate your use of Stores and purchase of fresh food products;
- to provide you with information, products, or services that you request from us;
- to fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it;
- to provide you with notices about your Account, including expiration and renewal notices;
- to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
- to notify you about changes to our App or any products or services we offer or provide through it;
- to improve our App, or any related products or services, marketing, or customer relationships and experiences;
- to allow you to participate in interactive features, social media, or similar features that may appear from time to time on our App;
- to measure or understand the effectiveness of the advertising we may from time to time present to you and others, and to deliver relevant advertising to you;
- in any other way we may describe when you provide the information; or
- for any other purpose with your consent.
We may also use your personal information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please email us at support@nakahealthyfoods.ca. For more information, see Choices About How We Use and Share Your Information.
We may, but do not necessarily, use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- to present our App and its contents to you;
- to facilitate your use of Stores and purchase of fresh food products;
- to provide you with information, products, or services that you request from us;
- to fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it;
- to provide you with notices about your Account, including expiration and renewal notices;
- to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
- to notify you about changes to our App or any products or services we offer or provide through it;
- to improve our App, or any related products or services, marketing, or customer relationships and experiences;
- to allow you to participate in interactive features, social media, or similar features that may appear from time to time on our App;
- to measure or understand the effectiveness of the advertising we may from time to time present to you and others, and to deliver relevant advertising to you;
- in any other way we may describe when you provide the information; or
- for any other purpose with your consent.
We may also use your personal information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please email us at support@nakahealthyfoods.ca. For more information, see Choices About How We Use and Share Your Information.
We may, but do not necessarily, use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
How and When We Share Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may, but do not necessarily, disclose personal information that we collect as described in this policy:
- to any of our subsidiaries and affiliates which may exist from time to time;
- to food suppliers, contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with App improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy;
- in accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our customers and users is among the assets transferred;
- to advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, mothers in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers’ advertisements to that target audience;
- to third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Share Your Information;
- to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with App improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information; or
- with your consent.
We may also disclose your personal information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
- to enforce or apply our Terms of Use or other agreements, including for billing and collection purposes; or
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Retention of Your Information
You specifically acknowledge and consent to our storing of your personal information in servers offshore, including in the European Union (“EU”). By submitting your data and/or using the App, you consent to the transfer, storing, and processing of your data in and to the EU. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the relevant EU country may be able to obtain access to your personal information through the laws of that EU country.
Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
You have the right to request that we erase some of your personal information, under certain conditions. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Please note that your personal information may remain in our archived records after your account has been deactivated.
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information.
Securing Your Information
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.
Choices About How We Use and Share Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this App may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies / Other Automatic Collection Technologies.
- Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form where we collect your data. You can also opt-out by logging into the App and using one of the tools provided by us, or by sending us an email stating your request to support@nakahealthyfoods.ca.
- Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into the App and using one of the tools provided by us, or by sending us an email stating your request to support@nakahealthyfoods.ca. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.
Accessing and Correcting Your Information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
You can review and change your personal information by logging into the App and visiting your account profile page.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at support@nakahealthyfoods.ca to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- information protected by solicitor-client privilege;
- information that is part of a formal dispute resolution process;
- information that is about another individual that would reveal their personal information or confidential commercial information; or
- information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact us at support@nakahealthyfoods.ca.
Withdrawal of Consent
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support@nakahealthyfoods.ca. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. Withdrawing consent may in some circumstances require that you deactivate the App and your Account. We will explain the impact to you at the time to help you with your decision.
As discussed, you can always choose not to provide certain information to us but you may not be able to use certain features of the App. If you do not wish to receive promotional communications from us, you can opt-out by: (i) following the unsubscribe instructions provided in the promotional communication you receive; or (ii) where available, managing your email preferences by signing into your Account on the App. Please note that despite your opt-out choice or indicated email preferences, we will still send you administrative messages, including, for example, administrative confirmations, order confirmation, important updates and notices regarding our policies.
Please be aware that even after your Account is terminated or deleted some or all of your information may still remain visible to others. A request to delete and/or termination of your Account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to the Company.
Changes to This Policy
We include the date this policy was last revised at the top of this page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our App and this policy to check for any changes.
We will post any changes we make to this policy on this page with a notice that the policy has been updated on the App home page.
Children Under 13
Our App is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the App. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this App or on or through any of its features/register on the App, make any purchases through the App, use any of the interactive or public comment features of this App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@nakahealthyfoods.ca.
Users Outside Canada
If you are using the App from outside Canada, you should be aware that, depending on the country you are in, domestic privacy laws may provide you legal protections regarding your personal information. These protections may be different than those in Canada.
Europe
Users in European countries are covered by the personal information protections in the European Union General Data Protection Regulation (EU) 2016/679 (“GDPR”). Such users have certain rights, which may include the right to view, correct or delete his/her/its personal data, the right to data transferability, and the right to withdraw his/her/its consent for data processing or to object to the processing of his/her/its personal data by Serene. This means that such person, including a Client of ours, can submit a request to us to send the personal data that we hold about such person in a computer file to him/her/it or another organization mentioned by him/her/it.
In order to exercise any of these rights, a written request can be submitted to Company at support@nakahealthyfoods.ca for access, correction, deletion, data transfer of the personal data or request for withdrawal of consent or objection to the processing of such person’s personal data, together with a copy of the person’s proof of identity. In the copy of proof of identity, it is advisable to conceal the passport photo, MRZ (machine readable zone, the strip with numbers usually at the bottom of the passport), passport number and citizen service number, so that these items are not legible.
USA
In the United States, there is no federal level statute governing the protection of personal information, but several states have enacted such statutes. The most important state-level privacy legislation is found in California.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
Schedule “A” to this policy contains terms applicable specifically to California residents who use the App as Clients (the “California Policy”).
Many parts of the California Policy are identical to those in this policy. To the extent possible, the California Policy should be read in harmony with this policy and our Terms of Use, and if there is any conflict between the two, the California Policy shall prevail in relation to any California resident’s use of the App as Clients.
California’s “Shine the Light” law (Civil Code § 1798.83) permits users of the Services that are California residents 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 e-mail to support@nakahealthyfoods.ca.
Contact Information
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us at support@nakahealthyfoods.ca.
Naka Healthy Foods Inc. cob as Naka Healthy Foods
4030 8 St SE
Calgary, Alberta, Canada
T2G 3A7
Schedule “A” – For Users in California
Policy for California Users
This Privacy Policy for California Residents (“California Policy”) supplements the privacy policy of Naka Healthy Foods Inc. (“we”, “us”, “our(s)”) , and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this California Policy.
This California Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Where noted in this California Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.
Collection
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996(HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act(FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social insurance number, driver’s license number, passport number, or other similar identifiers. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, social insurance number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. 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, 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 |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
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 |
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. | NO |
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. | YES |
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our App.
Use
We may use or disclose 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 App, 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 App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our App, 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 App, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our App, 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 the CCPA.
- 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 App users is among the assets transferred.
We 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.
Sharing
We may share your personal information by disclosing it to a third party for a business purpose. We do not sell personal information.
We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
Personal Information Category | Category of Third-Party Recipients | |
Business Purpose Disclosures | Sales | |
A: Identifiers. | Registration and use of the Services. | None. |
B: California Customer Records personal information categories. | Registration and use of the Services. | None. |
C: Protected classification characteristics under California or federal law. | Registration and use of the Services. | None. |
D: Commercial information. | Registration and use of the Services. | None. |
E: Biometric information. | None. | None. |
F: Internet or other similar network activity. | Registration and use of the Services. | None. |
G: Geolocation data. | None. | None. |
H: Sensory data. | None. | None. |
I: Professional or employment-related information. | None. | None. |
J: Non-public education information. | None. | None. |
K: Inferences drawn from other personal information. | Registration and use of the Services. | None. |
Your California Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
We do not provide a right to know or data portability disclosure for B2B personal information.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by
- emailing us at support@nakahealthyfoods.ca;
- visiting www.nakahealthyfoods.ca
- writing to us at Naka Healthy Foods Inc. cob as Naka Healthy Foods, 4030 8 St SE, Calgary, Alberta, Canada T2G 3A7
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may also make a request to know or delete on behalf of your child by the same method.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include (i) two (2) pieces of government-issued photo from a state, provincial, or federal government or (ii) parental or guardian identification information; 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.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact support@nakahealthyfoods.ca.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 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 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 useable and should allow you to transmit the information from one entity to another entity 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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Contact Information
If you have any questions or comments about this notice, the ways in which Proto collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at
Naka Healthy Foods Inc. cob as Naka Healthy Foods
4030 8 St SE
Calgary, Alberta, Canada
T2G 3A7
Changes to This California Policy
We reserve the right to amend this California Policy at our discretion and at any time. When we make changes to this California Policy, we will post the updated notice on the App and update the notice’s effective date. Your continued use of our App following the posting of changes constitutes your acceptance of such changes.