At The 360 Degrees Health & Wellness Company (“360”), we are committed to providing our customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers, protecting their personal information is one of our highest priorities.
We will inform our customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Scope of this Policy
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of 360, but does not apply to any third-party websites linked from our websites, as such websites are governed by their own privacy policies.
Personal Information –means information about an identifiable individual, such as their name, date of birth, gender, home address, personal phone number, personal email address, Internet Protocol (IP) address, personal interests and shopping preferences. Personal information does not include business contact information (described below).
Personal Health Information – Personal Health Information (“PHI”) is Personal Information that is related to a person’s health or the provision of health services to them. Examples are: medical histories, test and laboratory results, mental health conditions, insurance information and other Personal Information that we use to provide quality care and services and to meet our legal and professional requirements.
Business Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. This is information that would normally be found on someone’s business card. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that 360 complies with this policy and PIPA.
360 has adopted privacy principles consistent with the Canadian Standards Association’s “Model Code for the Protection of Personal Information”. The code contains ten (10) information principles that are generally described as follows:
1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will collect customer personal information that is necessary to fulfill the following purposes:
2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, or electronically, through an authorized representative, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of their personal information being used and the customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers can withhold or withdraw their consent for 360 to use their personal information in certain ways. A customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s knowledge or consent in the following limited circumstances:
Using and Disclosing Personal Information
3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
3.2 We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so.
Retaining Personal Information
4.1 If we use customer personal information to make a decision that directly affects the customer, we will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.
5.2 Customers may request corrections to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer or designated individual.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customers’ correction request in the file.
Securing Personal Information
6.1 We are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer personal information is appropriately protected:
6.3 We will use appropriate security measures when destroying customer’s personal information such as shredding documents and deleting electronically stored information].
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Providing Customers Access to Personal Information
7.1 Customers have a right to access their personal information, subject to limited exceptions:
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer or designated individual.
7.3 Upon request, we will also tell customers how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer of the cost and request further direction from the customer on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer in writing, providing the reasons for refusal and the recourse available to the customer.
Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring 360’s compliance with this policy and PIPA (and any other applicable legislation).
8.2 Customers should direct any complaints, concerns or questions regarding 360’s compliance in writing to 360’s designated Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for 360’s Privacy Officer:
The 360 Degrees Health & Wellness Company
#206 – 10183 152A Street
Surrey, BC V3R 4H6
Attention: Privacy Officer
We will respond to your request or concern as soon as possible.