We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time. We will post the current version of this policy at: www.sunnapure.com/privacy
WHAT IS PERSONAL INFORMATION?
If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact Sunna Inc.'s Privacy Officer for guidance or clarification.
WHAT PERSONAL INFORMATION WE COLLECT
Sunna Inc. collects and uses only the personal information that we need for providing services and operating our business. The various purposes for collecting personal information are set out in this policy. Any necessary consents shall be obtained before personal information is collected, used or disclosed. We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask you to provide your consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button). In cases that do not involve sensitive personal information, we may rely on "opt-out" consent.
The amount and type of personal information collected by Sunna Inc. shall be limited to what is necessary to fulfill the identified purpose(s). Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law.
Personal information collected by Sunna Inc. or on behalf of Sunna Inc. will be stored at Sunna Inc's office in Calgary, Alberta and will be subject to the laws of Canada. Your information is also stored on our servers located in Canada and/or United States of America.
Please note that we use cloud-based services to store information. Where personal information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction's governments, courts or law enforcement or regulatory agencies.
Generally, Sunna Inc. collects the following personal information from individuals for the various purposes set out in the paragraph below:
Email address, phone number and other contact information; Depending on the service(s) used, sometimes financial information, such as credit card and/or bank account numbers;
Transactional information based on your activities at physical company locations as well as any websites transaction (such as reserving, bidding, buying, selling items and/or content you generate or that relates to your account);
Payment, billing and other information you provide to purchase or products or services (as that term is defined in our Terms & Conditions);
Community discussions, chats, dispute resolution, correspondence through our websites, social media and correspondence sent to us;
Other information from your interaction with our Company, websites, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the websites, ad data, IP address and standard web log information;
Additional information we ask you to submit to authenticate yourself or if we believe you are violating Company policies (for example, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity or ownership of an item you list);
Information from other companies, such as demographic and navigation data; and
Other supplemental information from third parties (for example, if you incur a debt to Sunna Inc., we will generally conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by law).
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information for the following purposes:
Provide the services and customer support you request;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent, detect, and investigate potentially prohibited or illegal activities, and enforce our User Agreement;
Customize, measure and improve our services, content and advertising;
Tell you about our services and those of our corporate family, deliver targeted marketing, service updates, and promotional offers based on your communication preferences;
Compare information for accuracy, and verify it with third parties;
Other uses as described when we collect the information; and
As otherwise authorized or required by law.
We normally collect personal information directly from the individual concerned. We may collect your information from other persons with your consent or as authorized by law. Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent.
In addition, we may also receive and send data from our servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our website, if any. We may use tracking technologies in a variety of ways, including the following: keeping count of return visits to our website; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best.
DISCLOSURE OF YOUR INFORMATION
We may disclose personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.
We may also share your personal information with: Members of the Sunna Inc. corporate family, to provide joint content and services (like registration, transactions and customer support); Members of our corporate family will use this information to send you marketing communications only if you've requested their services; Service providers under contract who help with our business operations (such as fraud investigations, bill collection, and affiliate and rewards programs; Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service); Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity; Other business entities, should we plan to merge with or be acquired by that business entity in accordance with applicable laws.
INFORMATION YOU SHARE ON SUNNA INC.
Your personal details are available securely throughout Sunna Inc. however are not available to the public, and is connected to all of your Sunna Inc. activity.
If you access our websites or shopping portals from a shared computer (such as a computer in an public Wi-Fi hotspot), certain information about you, such as your User ID, activity or reminders from Sunna Inc., may also be visible to other individuals who use the computer after you.
USING INFORMATION AT SUNNA INC.
Sunna Inc. enables you to share personal and financial information to complete transactions and collect payments. To help protect your privacy, we allow only limited access to your personal and financial information to facilitate your transactions and collect payments.
We don't sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising. If you don't wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference in your Sunna Inc. User Account preferences or by following the directions provided with the communication or advertisement.
Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law.
You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
OBTAINING ACCCESS TO PERSONAL INFORMATION
Upon request received by Sunna Inc. in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information, subject to restrictions found in applicable privacy legislation, if any. Requests to access personal information held by Sunna Inc. should be directed to Sunna Inc's Privacy Officer.
Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such documentation provided shall be used for verification purposes only.
Sunna Inc. responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation. A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee.
Requested information will be provided in a form that is generally understandable.
Sunna Inc. will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information, Sunna Inc. will provide a list of organizations to which it is likely to have disclosed information.
Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from Sunna Inc, individuals wishing to view an original record will do so at Sunna Inc's head office and under the supervision of designated Sunna Inc. personnel.
LIMITATION TO ACCESS
Sunna Inc. will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.
In the event that Sunna Inc. refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Sunna Inc. will respond to your requests for access in accordance with applicable privacy legislation.
MAINTENANCE OF PERSONAL INFORMATION
You can see, review and change most of your personal information by contacting Sunna Inc. Generally, we will not manually modify your personal information. You must promptly update your personal information if it changes or is inaccurate. Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable law. We do retain personal information from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Sunna Inc. any Customer Agreement or Terms & Conditions, and take other actions otherwise permitted by law.
Personal information will be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used. Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by Sunna Inc. and have it amended as appropriate.
Individuals seeking a correction or amendment to their personal information should direct their requests in writing to Sunna Inc's Privacy Officer.
All formal requests to amend personal information must be accompanied by appropriate supporting documentation. Sunna Inc's Privacy Officer will manage any exceptions. The amended information will be transmitted to third parties, as appropriate.
If the individual is not satisfied with the results of the request, Sunna Inc shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.
SECURITY OF PERSONAL INFORMATION
Personal information will be retained only as long as necessary and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.
We treat data as an asset that must be protected and use a number of tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorized access and disclosure.
We will notify the appropriate authorities, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.
If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.
QUESTIONS AND CONTACT US DETAILS
If you have a question or concern about any collection, use or disclosure of personal information by Sunna Inc and/or third party service providers, or would like to request access to your own personal information, please contact:
2110 54 Ave SW, Calgary, AB T3E 1L7
PRIVACY OFFICER: firstname.lastname@example.org
Last Updated: May 8, 2020