Any information gathered is stored by Lesley Stowe within North America.
- any other websites, ecommerce stores, servers, online portals, web portals, mobile applications and electronic user interfaces;
- any social media pages, email messages, text messages and direct messages;
- any phones, computers, web cameras and other communication devices operable to receive your written, text, oral, telephonic and video communications;
- any real time communications with our representatives, including interviews, discussions, conversations and conferences via in-person interaction or video, phone or other means;
- any brick-and-mortar facilities (such as stores, offices, trade show buildings and convention centers) as well as any cameras, beacons, sensors and other tracking equipment located at such facilities;
- any means for personal interaction or observation, such as the collection of survey results from you when you are located at such facilities; and
- any surveys, forms and other materials used to document your answers, feedback or behavior at such facilities.
2. WHAT PERSONAL INFORMATION DOES LESLEY STOWE COLLECT?
Consumers: Lesley Stowe may collect personal information about consumers when they submit information to our Marketing Platform, call our Consumer Services Contact Center or otherwise communicate with us (e.g. to enter a contest, request information or mailings, buy a product or service, participate in a survey, complete a review, or any other interaction with Lesley Stowe).
Third Parties: In limited circumstances, Lesley Stowe may collect personal information about third parties, but only once provided by a consumer. Lesley Stowe does not solicit third party personal information. For example, some of our websites offer visitors the ability to send information to a friend by email (a recipe). A visitor may provide us with his or her friend’s name and email address. Please note that Lesley Stowe will use such information only for the specified purpose (e.g. to send the recipe). Lesley Stowe will not contact the third party again or use or disclose the third parties’ personal information without the knowledge and consent of the third party. Children: Lesley Stowe is committed to protecting the privacy of children and we do not knowingly solicit information from children under the age of 13. If a child under the age of 13 wishes to send us personal information, he or she is required to provide Lesley Stowe with his or her parent’s or guardian’s email address so that we can obtain permission. If a child has already provided us with personal information, his or her parent or guardian may contact us for the purpose of correcting or deleting this information (please see, “Who to Contact” in Section 10 below). If we discover that a child under the age of 13 has provided us with personal information, we will undertake all reasonable efforts to delete such personal information. We encourage parents of children under the age of 13 to regularly check and monitor their children’s use of email and the Lesley Stowe website.
3. WHY DOES LESLEY STOWE COLLECT PERSONAL INFORMATION?
- to understand consumer needs and preferences in order to best provide our services to you;
- to communicate with Marketing Platform visitors and consumers;
- to administer the Lesley Stowe Consumer Care Center and to respond to consumer inquiries;
- to conduct surveys, contests and promotions;
- to conduct research and statistical analysis to understand usage, activity trends, and purchasing patterns, in order to assist with advertising initiatives;
- where permitted by law, to distribute Lesley Stowe customized content including newsletters, promotional information, product samples, coupons and other material to individuals who have voluntarily enrolled in our mailing lists and/or emailing lists, including via third party mailing houses;
- to develop, enhance, market, sell, provide and inform individuals of, Lesley Stowe products and services;
- to develop, enhance, market, sell, provide and inform individuals of, products and services of third parties, including our affiliates and suppliers, with whom Lesley Stowe has a commercial relationship;
- to update and verify Lesley Stowe databases and information provided by third parties;
- to ensure the consistency and quality of the products and services of Lesley Stowe, in communicating with Lesley Stowe’s affiliates, suppliers, distributors, retailers and other third parties with whom Lesley Stowe has a commercial relationship and with which personal information must reasonably be disclosed to maintain said commercial relationship;
- with respect to individual service providers, suppliers, distributors and retailers, limiting disclosure to the least amount necessary to achieve the necessary purposes herein described, to: (1) consider whether Lesley Stowe or any of its affiliates should establish or continue a commercial relationship, including without limitation, to extend credit and to evaluate credit standing and to match credit bureau or credit reporting agency information, to check references and to confer with banking institutions; and (2) establish and maintain commercial relationships, to provide products and services, administer accounts, make and receive payments, facilitate product delivery and returns, and fulfil contractual obligations;
- to detect and protect Lesley Stowe and other third parties against error, negligence, breach of contract, fraud and other illegal activity, and to comply with Lesley Stowe audit requirements, and to audit compliance with Lesley Stowe policies, procedures, laws and contractual obligations;
- to engage in business transactions that may involve the transferring or supplying a copy of your personal information to a third party that acquires any portion of our business, assets, stock or equity in connection with a reorganization, merger, sale, joint venture, contractual assignment, transfer or other transaction, including any bankruptcy or similar proceeding involving Lesley Stowe or its affiliates or any particular brand, product line or business unit;
- as permitted by, or to comply with, any laws or regulations, including but not limited to, for the purpose of collecting a debt owed by the individual to the organization, to comply with a subpoena or warrant issued or an order made by the court or any administrative body or person with competent jurisdiction to compel disclosure;
- for any other purpose to which an individual provides knowledgeable and informed consent;
- to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or to prosecute those responsible for that activity;
- for debugging to identify and repair errors that impair existing intended functionality of our Marketing Platform;
- to exercise free speech, ensure the right of another consumer to exercise the consumer’s right of free speech, or exercise another right provided for by law;
- to 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 our deletion of your personal information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent; and
- to evaluate prospective employees and agents, and to hire such employees and agents.
4. HOW DOES LESLEY STOWE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION
Identifying Purposes for Collection of Personal Information
Lesley Stowe identifies the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which Lesley Stowe currently collects, uses or discloses personal information are described in Section 3 above.
Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of his or her personal information, except as permitted by law. In obtaining consent, Lesley Stowe uses reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information will be used or disclosed. In determining the appropriate form of consent, Lesley Stowe takes into account the sensitivity of the personal information and the reasonable expectations of a reasonable person. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. At that time, Lesley Stowe will advise the individual of the implications of such withdrawal.
Limiting Collection of Personal Information
Lesley Stowe limits the collection of personal information, both the amount and the type of information, which is necessary for the purposes identified by Lesley Stowe. Lesley Stowe collects personal information by fair and lawful means, and not by misleading or deceiving individuals about the purpose for which information is being collected.
Limiting Use, Disclosure, and Retention of Personal Information
Lesley Stowe does not use or disclose personal information for purposes other than the identified purposes for which it is collected, except with the consent of the individual or as required or permitted by law. Lesley Stowe retains personal information only as long as is necessary to fulfil the identified purposes.
Accuracy of Personal Information
Personal information held by Lesley Stowe is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an individual. Lesley Stowe does not routinely update personal information, unless such process is necessary to fulfil the identified purposes. We rely on individuals to inform us of any changes to their personal information. To update your personal information, please see Section 10 below.
Lesley Stowe protects personal information by security safeguards appropriate to the sensitivity of the information. Lesley Stowe uses reasonable efforts and security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction.
Openness Concerning Policies and Practices
Individual Access to Personal Information
In response to the written request from an individual, Lesley Stowe will inform the individual of the existence, use, and disclosure of his or her personal information and, subject to certain exceptions provided by law, will give the individual a reasonable opportunity to review the personal information collected by Lesley Stowe who will make every reasonable effort to provide personal information in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. If access is denied, Lesley Stowe will inform the requesting individual in writing.
No Sale of Your Personal Information
Lesley Stowe does not, and will not, sell any of your personal information.
5. TO WHOM DOES LESLEY STOWE DISCLOSE PERSONAL INFORMATION?
- a person who, in the reasonable judgment of Lesley Stowe, is providing or seeking the information as an agent of the subject individual, such as a parent or guardian of a child under the age of 13;
- service providers or third parties retained by Lesley Stowe to perform functions on its behalf or to provide services to Lesley Stowe, such as advertisers, promotion and mailing houses, market researchers, delivery contractors, auditors, website administrators, data processing, information technology and office services, provided such organization or individual does not collect, use or disclose the personal information for any purpose other than to perform such functions or provide services to Lesley Stowe; or
- any third party where the subject individual consents to such collection, use or disclosure, or as required or permitted by law.
6. PRIVACY AND LESLEY STOWE WEBSITE
Online and Offline Communications
In order to provide you with a product, service or information, you may voluntarily submit personal information to us for purposes such as registering for our services, obtaining information, corresponding with us, and participating in contests and surveys. Voluntarily submission of your personal information is deemed as explicit consent to collect, use, or disclose your personal information in accordance with this policy. We may combine and store personal information about your use of our Marketing Platform and the online information you have provided with certain other online and offline information we may have collected.
If you subscribe to any of our e-newsletters or other similar website services, Lesley Stowe may send you email communications with information that may be useful to you, including information about the products and services of Lesley Stowe, its affiliates and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional emails from Lesley Stowe. In addition, at any time you may let us know that you wish to discontinue such mailings or contact by contacting the Consumer Care team. If you opt-out of receiving emails about recommendations or other information we think may interest you, Lesley Stowe reserves the right to still send you transactional emails about your account, including confirmation of payment or any other necessary Services you have requested or received from us.
7. California Residents
Under California Civil Code Section 1798.83 (also known as Information-Sharing Disclosure, Shine the Light), if you are a California resident and your business relationship with us is primarily for personal, family, or household purposes, you may request certain data regarding our disclosure, if any, of your personal information to third parties for the third-parties’ direct marketing purposes. To make such a request under this California law, please contact us in accordance with Section 10. You may make such a request up to once per calendar year. In accordance with this California law, we will provide to you, by e-mail, a list of the categories of any of your personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses and any other information required by this California law.
8. European Union Residents
Legal Bases for Processing Personal Information
- it is necessary for us to process such personal Information for purposes of: (a) performing contracts between you and us, including contracts involving our sale of products or services to you; (b) protecting your vital interests; or (c) establishing, exercising or defending legal claims;
- it is necessary for reasons of substantial public interest;
- it is necessary for reasons of public interest in the area of public health;
- it is necessary for archiving purposes in the public interest or for scientific or historical research purposes or statistical purposes;
- you have publicly disclosed such personal information that we process; and
- we process such personal information for purposes of our legitimate interests.
If we desire to process any of such personal information for cases that require your prior consent pursuant to the GDPR, we will not do so without obtaining your prior consent in accordance with the GDPR.
Transfers of Personal Information
To the extent we transfer any personal information from any member-country of the European Union to any other country, we will satisfy the conditions required for such transfer under the GDPR and other applicable laws. For example, depending on the circumstance, we may implement any of the following measures to satisfy such conditions: (a) appropriate safeguards to protect such personal information, including binding corporate rules, standard data protection clauses, an approved code of conduct, an approved certification mechanism, or any other measure set forth in the GDPR, provided that, in each such case, we will implement the applicable measure in accordance with the requirements of the GDPR; or (b) a procedure or measure to confirm that: (i) such transfer is necessary or that you have explicitly consented to such transfer; (ii) such the transfer is not repetitive, concerns only a limited number of data subjects, and is necessary for the purposes of compelling legitimate interests pursued by us; and (iii) we have satisfied the additional requirements set forth in the GDPR.
10. WHO TO CONTACT, AND MAKING CHANGES TO YOUR PERSONAL INFORMATION
- to correct, update or delete your personal information from our records
- to correct, update or delete personal information that your child under age 13 has provided to Lesley Stowe
- to unsubscribe from mailings and other Lesley Stowe mailings
Alternatively, you may contact us regarding these matters by mailing a letter to the following address:
Lesley Stowe (a division of Dare Foods Ltd)
25 Cherry Blossom Rd,
Cambridge, Ontario, N3H 4R7, Canada
Attention: Legal Department
Lesley Stowe Service Providers, Suppliers, Distributors, Retailers and for all other privacy-related inquiries:
11. CROSS BORDER TRANSFERS/STORAGE
12. UNSOLICTED INFORMATION
13. POLICY UPDATES
Date Last Revised: February 26, 2021
Effective October 6, 2004
Description of Revisions: General revisions
© 2021 Lesley Stowe (a division of Dare Foods Ltd)