Last updated May 1, 2019
Our commitment to privacy
Soma Wellbeing Inc. (operating as “Jolanta’s European Spa") (the “Corporation”, “we”, “our”) is committed to protecting the privacy and security of your personal information obtained by reason of your customer relationship with the Corporation. This policy explains the types of customer personal information we collect, how it is used, and the steps we take to ensure that your personal information is handled appropriately.
What is personal information?
Personal information is information that refers to an individual specifically or information about an individual which is personally identifiable and is recorded in any form. Personal information includes such things as name, address, phone number, e-mail address, age, income, date of birth, ethnic origin and credit records.
Non-personal information is information which does not identify you as an individual. Publically available information is also not considered personal information, such as, information displayed in public telephone directories where the subscriber can refuse to be listed, professional and business directories available to the public, public registries and other publicly available printed and electronic publications.
Use of personal information
The Corporation is responsible for all personal information under its control, including any personal information that is transferred to third parties for processing, storage or other purposes. We may collect and use your personal information for some or all of the purposes listed below. You will be deemed to consent to our use of your personal information for the purpose of:
• communicating with you generally;
• responding to your questions or inquiries;
• processing your product and service purchases;
• providing products and services requested by you;
• processing and keeping track of transactions and reporting back to you;
• protecting against fraud or error;
• conducting market research and surveys;
• conducting promotional activities, including contests;
• recommending products and services that the Corporation believes will be of interest to you;
• improving our products, services and Website;
• complying with legal and governmental requirements;
• fulfilling any other purpose that would be reasonably apparent to the average person at the time we collect it from you.
We may transfer your Personal Information to third party service providers that assist us with carrying out these purposes. For example, we may use third party service providers to facilitate payments.
We may also use or disclose your Personal Information to third parties if we have reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter, for example, if we are subject to a subpoena, court order, or the information is requested by the police or another law enforcement entity; or (iv) to protect our rights, safety or property.
Otherwise, the Corporation will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your personal information for purposes other than as listed above. You can change your consent preferences at any time by contacting the Corporation. To change your preferences, refer to the “How to contact us” section below.
Collection of information
The Corporation collects only the information required to provide products and services to you. The Corporation will collect personal information only by clear, fair and lawful means.
We receive and store any information you enter on our Website or give us in any other way such as by phone, e-mail, on paper and in person. You can choose not to provide certain information, but then you might not be able to take advantage of our products, services or Website.
Information we collect automatically
Like many other websites, we also receive and store certain types of information whenever you interact with us online. For example, we use “cookies,” and we obtain certain types of information when your web browser accesses our Website. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser, to enable our systems to recognize your browser and to provide features. This non-personal information is used for Website and system administration purposes.
Sharing your information
The Corporation does not disclose personal information to any organization or person for any reason, except the purposes listed below. If your personal information is shared with third parties, those third parties are bound by appropriate agreements with the Corporation to secure and protect the confidentiality of your personal information. You are deemed to consent to disclosure of your personal information for the following purposes:
• We may employ other companies and individuals to perform functions on our behalf. Information is shared with such companies and individuals only to the extent and for the purposes necessary to perform their functions, but they may not use it for other purposes. We may use service providers located outside of Canada, and, if applicable, your personal information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries.
• As we continue to develop our business, we might sell or buy stores, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the customer consents otherwise). Also, in the unlikely event that the Corporation or substantially all of its assets are acquired, customer information of course will be one of the transferred assets.
Retention of information
The Corporation retains your personal information only as long as it is required for our business relationship or as required by federal and provincial laws. You may request that we remove your information from our records. Subject to our requirements for continued retention of your information, for example, for billing, audit, or warranty purposes, we will make every reasonable effort to honour your request.
How can I access my information?
You may request access to the personal information we have on record in order to review and amend the information, as appropriate. In circumstances where your personal information has been provided by a third party, we will refer you to that party (e.g. credit bureaus). To access your personal information, refer to the “How to contact us” section below.
Upon receiving a request to access your personal information, the Corporation will:
• verify your identity;
• inform you about what type of personal information we have on record or in our control, how it is used and to whom it may have been disclosed;
• provide you with access to your information so you can review and verify the accuracy and completeness and request changes to the information; and
• make any necessary updates to your personal information.
The security of your personal information is a priority
We take steps to safeguard your personal information, regardless of the format in which it is held, including:
• physical security measures such as restricted access to our facility and locked filing cabinets
• electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers;
• contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information.
It is important for you to protect against unauthorized access to your password and your computer. Be sure to sign off when you have finished using any shared computer.
Links to other websites
We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information. We will respond in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures.