Privacy

Customer Privacy Policy Updated December, 2010

Our Commitment

At Naturally You Skin Care & Cosmetics Inc we recognize that the protection of the privacy of your personal information is a very important principle in building and maintaining our relationship with you.

This Customer Privacy Policy describes the commitments of Naturally You Skin Care and the rights of our Customers regarding personal information under the Personal Information Protection and Electronic Documents Act (the “Act”) and is based on the Canadian Standards Association Model Code for the Protection of Personal Information.

The Customer Privacy Policy applies to the collection, storage, use, disclosure, protection, and accuracy of Personal Information collected and controlled by Naturally You Skin Care & Cosmetics Inc.

Definitions

• Collect – to gather, acquire, or obtain Personal Information from any source, including third parties.
• Consent – voluntary agreement with what is being done or proposed. Consent can either be express or implied. Express consent is given explicitly, either orally or in writing. Implied consent may reasonably be inferred from the action or inaction of the Customer.
• Direct marketing – direct communications targeted to Customers, including mail, telemarketing, fax or electronic mail.
• Personal Information – information about an identifiable Customer recorded in any form.
• Supplier – a company under contract to provide services, data collection, or processing services to Naturally You Skin Care.

Summary Of Principles

PRINCIPLE 1: Accountability

Naturally You Skin Care is responsible for the Personal Information under its control, including Personal Information disclosed by Naturally You Skin Care to a Supplier and shall designate one or more persons who are accountable for compliance with the Customer Privacy Policy and the Act.

1.1

The Executive Management is accountable for Naturally You Skin Care’s compliance with the Customer Privacy Policy and the Act.

1.2

Naturally You Skin Care has appointed executive management individuals and, with the assistance of outside Corporate Counsel, this person(s) oversee(s) Naturally You Skin Care’s compliance with the Customer Privacy Policy and the Act.

1.3

Naturally You Skin Care uses legal agreements to provide a comparable level of protection for Personal Information while the information is being processed by an authorized Supplier.

1.4

The Management of Naturally You Skin Care has developed procedures to implement the Customer Privacy Policy and the Act. They include:

•           Procedures to protect Personal Information;

•           Procedures to receive and respond to complaints and enquiries;

•           Procedures to inform and train our employees on privacy policies and procedures; and,

•           Making available information about the Customer Privacy Policy to Customers.

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PRINCIPLE 2: Identifying Purposes

Naturally You Skin Care shall identify the purposes for which Personal Information is collected at or before the time the information is collected.

2.1

Naturally You Skin Care provides Customers with information that explains why the Personal Information is needed and how the Personal Information will be used or disclosed.

2.2

Naturally You Skin Care obtains consent of Customers before using Personal Information for a purpose that has not been specified, unless the new purpose is required by law.

2.3

Naturally You Skin Care collects Personal Information for the following purposes:

• to direct market to Customers;
• to understand and analyze Customer sales, needs and preferences;
• to develop, enhance, market and provide products and services to meet Customer’s needs;
• to enable Customers to participate in promotions and contests;
• to enable Customers to participate in Customer research or focus groups;
• to process exchanges or product returns;
• improve our Shops; and,
• to respond to requests or complaints.

Or by asking a Shop Manager or Sales Advisor to change his or her consent option to “No” on the Customer Maintenance screen in the database.

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PRINCIPLE 3: Consent

Every reasonable effort is made by Naturally You Skin Care to ensure that the Customer understands the purpose of the Personal Information. A Customer’s consent is obtained as required for the collection, use or disclosure of his or her Personal Information, except where it is inappropriate to do so.

3.1

Naturally You Skin Care provides information about the purpose of the Personal Information through printed materials, our Web site, its Customer Service Representatives and Shop Sales Associates.

3.2

Naturally You Skin Care obtains consent for the collection, use or disclosure of Personal Information. This consent is usually obtained verbally in Shop, or written registration form or on electronic enrolment forms, survey forms and/or during telephone conversations with Customers. It may also be obtained verbally from Customers through our Shop staff (for example, in conjunction with participation in our Customer Relationship Marketing program.)

3.3

Consent to provide Personal Information is not a condition for Naturally You Skin Care selling a product to Customers, unless the information requested is required to fulfill an explicitly specified and legitimate purpose.

3.4

At any time you can withdraw your consent to our collection, use or disclosure of your Personal Information by writing to:

Naturally You Skin Care – Privacy

Naturally You Skin Care & Cosmetics Inc

238 – 97 Carry Drive SE

Medicine Hat, AB

T1B 3M6

Or by e-mail to:

admin@naturallyyouskincare.com   

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PRINCIPLE 4: Limiting Collection

Naturally You Skin Care limits the amount and type of information it collects to what is necessary for the identified purposes.

4.1

Naturally You Skin Care does not collect Personal Information indiscriminately. The amount and type of Personal Information collected are limited to that which is necessary to fulfill the purposes identified.

4.2

Although the kind of Personal Information depends largely on the specific purpose, Naturally You Skin Care may typically collect the following Personal Information from its Customers:

• Name;
• address;
• phone number;
• date of birth;
• e-mail address;
• credit card number;
• gender;
• language preference; and
• merchandise category preferences.

4.3

Naturally You Skin Care collects Personal Information from the Customer:

• in-shop;
• through online and electronic sales transactions with Naturally You Skin Care;
• through interaction with our Customer Service Representative;
• through telephone, paper and online surveys and contests;
• through exchange and refunds of product transactions;
• through mail, email, fax or phone orders.

4.4

Information Naturally You Skin Care collects automatically.

Like many other websites, we automatically collect certain non-personal information regarding website users that does not identify you. Examples include the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the Site, the Internet address of the website from which you linked directly to the Site, the operating system you are using, the sections of the Site you visit, the Site pages read and images viewed, and the content you download from the Site.

4.5

Cookies. The Site uses “cookies”, a technology that installs a small amount of information on a website user’s computer to permit the website to recognize future visits using that computer. Cookies enhance the convenience and use of the Site. For example, the information provided through cookies is used to recognize you as a previous user of the Site (so you do not have to enter certain information every time), to offer personalized web page content and information for your use, to track your activity at the Site, to respond to your needs, and to otherwise facilitate your experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Site and your ability to access certain features of the Site or engage in transactions through the Site.

4.6

Tracking information. We may use non-personal information to compile tracking information reports regarding Site user demographics, Site traffic patterns, and Site purchases. None of the tracking information in the reports can be connected to the identities or other Personal Information of individual users.

4.7

Links to other websites. Our Site may contain links to other websites or Internet resources. When you click on one of those links you are contacting another website or Internet resource. Naturally You Skin Care has no responsibility or liability for or control over those other websites or Internet resources or their collection, use and disclosure of your Personal Information.

We encourage you to read the privacy policies of those other sites to learn how they collect and use information about you.

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PRINCIPLE 5 – Limit Use, Disclosure and Retention

Naturally You Skin Care does not use or disclose Personal Information for purposes other than those for which it is collected, except with the consent of the Customer or the use or disclosure is authorized by the Act or as required by law. Naturally You Skin Care only keeps Personal Information for as long as is necessary to satisfy those purposes.

5.1

Naturally You Skin Care does not give, rent or sell Customer lists to any organization or individual other than the business units of Naturally You Skin Care, its Franchisees, and Suppliers contracted to process and manage Customer transactions, analyze data, handle direct mailings or telemarketing, or arrange Customer research and focus groups.

5.2

As Naturally You Skin Care develops its business, it might sell or buy Shops or assets. In such transactions, Personal Information may be one of the transferred business assets. Also, in the event that Naturally You Skin Care or substantially all of its assets are acquired, Personal Information will be one of the transferred assets.

5.3

Naturally You Skin Care retains personal Information in accordance with guidelines and procedures established by Naturally You Skin Care. The Personal Information is collected and retained for as long as is necessary to satisfy identified purposes.

5.4

Naturally You Skin Care has procedures to govern the destruction of Personal Information that is no longer required to fulfill the identified purposes. Customer transaction records, Customer mailing lists, and Consumer Help Desk logs that are inactive after two (2) years are deleted from Naturally You Skin Care data base(s). “Inactive” means that no purchases or returns have been recorded during the previous twenty-four (24) consecutive-month period.

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PRINCIPLE 6 – Accuracy

Naturally You Skin Care keeps Personal Information as accurate, complete and up-to-date as necessary, taking into account its use and the interests of the Customer.

6.1

Naturally You Skin Care updates Personal Information as it is made available by Customers.

6.2

Customers are responsible for informing Naturally You Skin Care about changes to their Personal Information, as appropriate.

6.3

Naturally You Skin Care does not normally update Personal Information unless such a process is necessary to fulfill the purposes for which the Personal Information is collected.

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PRINCIPLE 7 – Use of Safeguards

Naturally You Skin Care protects Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held.

7.1

We use various methods to safeguard Personal Information. They include:

• physical measures, for example: locked filing cabinets, restriction of access to offices, and company alarm systems.
• technical tools, for example: passwords and encryption, using PGP encryption software.
• organizational controls, for example: confidentiality agreements, limiting access on a “need-to-know” basis, staff training and security clearances.

7.2

When Naturally You Skin Care uses a third party to process information on its behalf, legal agreements require the third party to protect the privacy and confidentiality of the Personal Information. Further, these agreements ensure that the Personal Information is retained only as long as necessary to complete the assigned task and that the Supplier only uses it for the specified purposes for which it is given.

7.3

Naturally You Skin Care has appropriate training programs and provides employees with information about its policies and procedures for protecting Customers’ Personal Information and the importance of maintaining the confidentiality of Personal Information.

7.4

Personal Information is disposed of or destroyed with care to prevent unauthorized parties from gaining access to the information.

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PRINCIPLE 8 – Openness

Naturally You Skin Care makes specific information about its policies and practices relating to the management of Personal Information readily available to its Customers.

8.1

Naturally You Skin Care is open about its policies and practices with respect to the management of Personal Information.

8.2

Naturally You Skin Care makes information about its privacy policies and practices available to its Customers through written materials (a copy of this Policy is available upon request), its Web Site (www.naturallyyouskincare.com), and its Consumer Help Desk.

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PRINCIPLE 9 – Individual Access

The Act gives you the right to access Personal Information that we have on file and receive an account of its use and disclosure. The Act also gives you the right to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.

9.1

All Customer requests for access to Personal Information held by Naturally You Skin Care must be in writing and directed to:

Naturally You Skin Care – Privacy

Naturally You Skin Care & Cosmetics Inc

238 – 97 Carry Drive SE

Medicine Hat, AB  T1B 3M6

by e-mail: admin@naturallyyouskincare.com    

Generally, Naturally You Skin Care will respond to a written request for access to Personal Information by informing the customer whether or not it holds Personal Information about that customer and by disclosing details of that customer’s Personal Information including, where available, the source, uses that have been made of the Personal Information, and third parties to whom it has been disclosed.

9.2

Naturally You Skin Care may request sufficient information from the Customer including adequate identification to verify the identity of the Customer when requesting access to the Personal Information held by Naturally You Skin Care. Naturally You Skin Care will assist any Customer who informs Naturally You Skin Care that he or she needs assistance in preparing a request for access.

9.3

Naturally You Skin Care responds to a request for information within thirty (30) business days of receipt of request.

9.4

Responding to a Customer request for information will usually be done at no or minimal cost to the Customer. However, a fee for reasonable costs incurred may be charged in responding to more complex requests, provided the Customer is informed of the fee in advance. The Personal Information requested is provided to the Customer in a form that is generally understandable.

9.5

The right to access to Personal Information is not absolute. In certain circumstances set out in the Act, Naturally You Skin Care must refuse access, for example, if access would reveal Personal Information about another person. In other circumstances, Naturally You Skin Care is permitted to refuse access, for example, where information is protected by solicitor/client privilege or the Personal Information was generated in the course of a formal dispute resolution. If Naturally You Skin Care is unable to provide access to all the Personal Information it holds about a customer, the reasons for denying access will be provided.

9.6

Naturally You Skin Care amends the Personal Information contained in Naturally You Skin Care database or elsewhere as required when an individual successfully demonstrates the inaccuracy or incompleteness of the Personal Information. Am amendment may involve the correction, deletion or addition of information. However, Naturally You Skin Care is unable to amend purchase information or return transaction information.

9.7

When it is not possible to provide a list of third parties or agents to which Naturally You Skin Care has disclosed Personal Information about a customer, Naturally You Skin Care provides a list of third parties or agents to which it may have disclosed such personal information about the customer.

9.8

A Customer has the opportunity to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate. When a challenge is not resolved to the satisfaction of the Customer, Naturally You Skin Care will keep a written record of the challenge, and the existence of the challenge is transmitted to third parties as appropriate.

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PRINCIPLE 10 – Challenging Compliance

A Customer is able to address a challenge concerning Naturally You Skin Care’s compliance with the above principles with the individual identified in Section 1.2.

 10.1

Naturally You Skin Care has procedures in place to receive and respond to inquiries about Naturally You Skin Care’s policies and practices relating to its handling of Personal Information. Any complaint should be in writing and directed to:

 Naturally You Skin Care – Privacy

Naturally You Skin Care & Cosmetics Inc. – Corporate Head Office

238 – 97 Carry Drive SE

Medicine Hat, AB

T1B 3M6

Or by e-mail to:

admin@naturallyyouskincare.com   

10.2

Naturally You Skin Care investigates all complaints and responds within thirty (30) business days after receipt of written correspondence. If the complaint is found to be justified, Naturally You Skin Care takes appropriate measures to resolve the complaint, including, if necessary, amending its policies and practices.

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