In this Policy, “we”, “us” and “our” refers to Northern Lights. When we say “you”, “user” or “individual(s)”, we are referring to the person accessing our Sites (non-customer or customer).
In this Policy, “Personal Information” means information about an identifiable individual such as name, email address, residential address, and telephone number. Personal Information also encompasses more sensitive information such as gender, age, health status, family information, and any other data assigned to an individual.
For additional information about our privacy practices when handling customer-specific Personal Information that is not collected by our Sites, please contact our Privacy Officer.
Northern Lights’ Privacy Officer is responsible for the creation, oversight, and implementation of our privacy management program and procedures to protect Personal Information, for receiving your privacy-related questions, and for providing you with information about our privacy practices.
You can contact our Privacy Officer at:
Northern Lights – Privacy Officer
249 Dufferin St, Toronto, Ontario, M6K 1Z5
Limited Collection and Use of Personal Information
Northern Lights collects, uses, and discloses Personal Information for the following purposes:
- to verify a user’s identity;
- to communicate with you on behalf of SALT and its trusted partners, some of which content may be paid advertisements (the “Partners”);
- to meet regulatory requirements; and
- to deliver relevant user content.
We will collect only the minimum amount of information that is required to meet these purposes; however, we also provide you with the voluntary option of sharing additional information (e.g., your geographical location, your product reviews, etc.) to enhance your and others’ experience with our Sites.
More specifically, SALT collects and uses the following information:
- First and Last Name
- Date of Birth
- Postal Code
- Province of residence
- Email address
To understand and improve the effectiveness of our email marketing efforts, when we send you a marketing email, we may collect information about whether you open the email, whether you access the link(s) provided and, if you do, what pages you visit on our Sites, and what, if anything, you purchase.
- Aggregate site use information:
We record information about the pages viewed by all of individuals who access our Sites. This data includes internet protocol (IP) address, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, connection speed, read time, display time, and number of clicks. We use this data, in aggregate form, to compile statistics and reports for Northern Lights use, and to improve the online experience for all visitors. We may, on occasion, provide portions of this aggregate information to vendors, consultants, potential advertisers, or news agencies. Typical uses of the data in this fashion would be to improve site functionality and evaluate the effectiveness of marketing initiatives.
- Mobile device:
If you use a mobile device to access the Sites, we may collect device information (such as your mobile device ID, model, and manufacturer), operating system and version information, IP address and geolocation information.
- Cookies, web beacons, pixel tags:
- Tracking and analytics:
- Cached data:
When you use our Sites, some data is cached in the memory of your device. Cached data is encrypted and kept on the device if you are logged in, even if the Sites are put in the background. The data is deleted from the device when you sign out of the Sites and does not remain on the device.
Disclosure of Information
Disclosure of Information by Northern Lights
For example, under certain circumstances, Northern Lights will disclose your Personal Information without first obtaining your consent to:
- Legal authorities: when we are required or authorized by law to cooperate with local, national or international law enforcement or other authorities for the reporting of and/or investigation of improper or unlawful activities, at the request of a third party, or if we believe disclosure is reasonable to comply with court orders, protect individual’s health and safety, or protect SALT’s rights and property.
- Trusted third parties: when the services we are providing to you require us to provide your information to a third party who performs functions on our behalf. Your information will be treated with the same level of privacy and security as we are committed to providing as an organization and will not be used for other purposes than that which we authorize.
Disclosure of Information by You
By you: You may disclose information when you post content to our websites or other public forums, such as our social media pages and blogs. Any information that you disclose through these services will become publicly available.
Collection of debt: Where it is necessary to establish or collect amounts owed to us.
Retention of Information
If you wish to have any of your information removed from our databases, or if you no longer want us to send any further communications to you, you can adjust your email settings through your online account or you can send an e-mail to firstname.lastname@example.org. Where your information is stored with our third parties, we will proceed as necessary to remove your information as requested. If you decide you no longer want us to send you further communications, we may still contact you for product safety reasons.
Northern Lights takes a consent-based approach to the collection, use, and disclosure of Personal Information. Subject to situations where consent is not legally required, we identify the purpose(s) for which we are collecting your Personal Information at or before the time we collect it. Depending on the nature and sensitivity of the Personal Information we collect, we will do one of the following: (1) obtain your express consent to the collection; (2) imply your consent to the collection from the fact that you have chosen to supply your Personal Information to us; or (3) consider that you have consented to the collection unless you have chosen to opt-out of providing consent where we have made an opt-out option available.
International Operations and Data Transfers
Unless there is a legal or regulatory requirement to store, access and/or use Personal Information in Canada, we may use third party platforms located outside of Canada to process and/or store Personal Information for us. Please note that Personal Information in the custody of these third-party platforms may be subject to access by the law enforcement authorities of those jurisdictions in which the third parties are located.
Our Privacy Officer can provide further information about our policies and practices regarding third party platforms located outside of Canada and further information about how they collect, use, disclose or store Personal Information on Northern Lights behalf.
Northern Lights relies on you to ensure that the Personal Information you provide to us while using the Sites and App is as accurate, complete, and up to date as necessary for the purposes for which it is to be used. You are welcome to make changes, request deletion or correction to Personal Information previously provided to Northern Lights can be up updated by emailing us at email@example.com.
Northern Lights uses administrative, technical, and physical safeguards to protect your Personal Information against loss, theft, and unauthorized access, use, disclosure, copying, modification, disposal, or destruction in accordance with applicable legal requirements and industry standards. For example, we implement encryption and security controls to protect against unauthorized access to Personal Information during electronic transmission and require third parties acting on our behalf to maintain reasonable and appropriate safeguards.
We will review and update our security policies and controls as technology changes to ensure ongoing security of your information, however, please bear in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you share with us.
At any time, you can review, edit, or request removal of information you have provided to SALT within the requirements as outlined in Retention of Information above. Upon written request, addressed to the Northern Lights Privacy Office, Northern Lights will also provide you with a list of entities to whom we have disclosed your Personal information.
Additional Features and Information
Northern Lights – Privacy Officer
249 Dufferin St, Toronto, Ontario, M6K 1Z5
Information and Privacy Commissioner of Ontario
2 Bloor Street East
Toronto, ON M4W 1A8
Long distance: 1.800.387.0073