Northlights Privacy Policy Northlights Privacy Policy

Northlights
Privacy Policy

This Website Privacy Policy explains how Northern Lights collects, uses, keeps safe and discloses Personal Information. It also explains the choices you have with respect to the information Northern Lights collects, uses, and discloses during your online experience via our website www.northlightsto.ca and its subdomains (collectively the “Sites”). Our privacy practices are based on and compliant with Ontario’s Personal Information Protection Act (“PIPA”), and Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), and the ten internationally recognized privacy principles.

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.

Accountability

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

privacyofficer@northernlightsto.ca

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:

All individuals

  • First and Last Name
  • Date of Birth
  • Postal Code 
  • Province of residence
  • Email address

Your email will be used for account generation, and it will also be used to contact you for the purposes of product information, service updates, and notifications relating to the Sites. With your consent and in accordance with Canada’s Anti-Spam Legislation (S.C. 2010, c. 23) (“CASL”) your Personal Information will be used to provide you with information for promotional and marketing purposes. At any time, you can opt-out of most email communication from us by clicking on the unsubscribe link at the bottom of our emails, updating your subscription preferences in your online user account, or contacting us. You can also opt out of receiving email communications from Ticket Fairy at any time by clicking on the unsubscribe link in emails you receive from them or contacting them using the information set out in their privacy policy (above).

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.

If you register for a contest or promotion, you will be required to acknowledge that you have read, understood, and agree to comply with the Terms of Use and this Privacy Policy, as they may be amended from time to time, for as long as you continue to use our Sites. If you do not agree with the Terms of Use or this Privacy Policy, do not sign up for an account, subscribe to our emails, and/or use our Sites.

  • 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:

    A cookie is a small text file stored on a user’s hard drive. Cookies are required to make purchases on our Sites. We also use cookies to assist with site traffic analysis, which includes tracking the time/date of visits, pages viewed, and referring URLs. We may use cookies to serve our remarketing campaigns so that third party vendors, which could include platforms like Google and Facebook, show our ads on sites across the Internet. We may also use web beacons or pixel tags to compile tracking information reports regarding website user demographics, website traffic patterns, and website purchases. None of the tracking information in these reports can be connected to the identities or other Personal Information of individual users. For our own research purposes, we may link tracking information with Personal Information provided by individuals who access the Sites. Once such a link is made, all the linked information is treated as Personal Information and will be used and disclosed only in accordance with this Privacy Policy.

  • Tracking and analytics:

    Northern Lights may use certain third-party analytics and/or ad serving services that also use cookies to monitor system usage, server, and software performance, to improve system design, to create benchmarks, and to conduct trending analyses. The providers of these services may independently collect, use, and disclose your IP address together with information about your visits to this and other websites that they service in accordance with their own privacy policies (and not this privacy policy). These third-party services may use their own cookies and other data collection technologies. They may use your browsing behaviour to improve your experience, to gain a view of how people are using websites that they service so that improvements can be made, and as otherwise permitted in their privacy policies. Northern Lights may also use targeted advertising service providers to tailor Northern Lights advertisements to your preferences. These advertisements may appear on Northern Lights website or social media sites, or on third party sites. If you do not consent to 3rd party analytics, please do not use our Sites or App. If you have opted in to receive email news or offers, Northern Lights may use your email address to target advertising to you. You may opt out of Northern Lights email advertising by clicking the unsubscribe link at the bottom of our emails, updating your subscription preferences in your online user account, or contacting us.

  • 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

Northern Lights will only disclose Personal Information for purposes identified in this Privacy Policy or for purposes that we expressly identify to you at the time we seek to collect your personal information. Otherwise, we do not sell, rent, or disclose your Personal Information to any third party without your consent unless disclosure without your consent is required or authorized by law.

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.

Social sharing: when you use certain aspects of Northern Lights website or other services, or you post information to other social networking sites (e.g. posting a link to Northern Lights Facebook or Instagram pages, or “liking” a product on your Facebook or Instagram account, or “pinning” a product on your Pinterest account), the Personal Information that you post or share in connection with these third party sites is visible to other persons and can be read, collected, used and disclosed by other persons. Any information provided to such third-party social networking sites and other sites is outside of Northern Lights’ control and is not governed by this Privacy Policy.

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 privacyofficer@northernlightsto.ca. 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.

Consent

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.

Accuracy

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 privacyofficer@northernlightsto.ca.

Safeguards

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.

Openness

Northern Lights makes clear and transparent notice of our privacy practices publicly available via this Privacy Policy and via the notifications that we provide to you at the time that we collect your Personal Information directly from you. You may contact our Privacy Officer to seek additional information about our privacy policies and practices.

Individual Access

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

It is important to guard your privacy when you are online. If our Sites contain links to other websites, those websites are not governed by this Privacy Policy. Whether we have posted those links or other organizations, or individuals have posted those links, you should read their privacy policies and make an informed decision about whether you want to use those websites or their services.

Where Northern Lights has enabled you to connect with other third-party platforms to use their services in conjunction with our Sites, you will be subject to their collection practices and the terms of use and privacy policies of those third-party platforms. You are responsible for reviewing and agreeing to those privacy policies, and terms and conditions. If you do not agree with the third-party terms of use or privacy policies, you should not use the services offered by such third-party service providers.

Changes to this Privacy Policy

We may update this Policy to reflect changes to our information practices. We will post any changes to this page and, if the changes are significant, we will provide a more prominent notice such as notification via email. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices and to contact us if you have any questions or concerns.

Challenging Compliance

Northern Lights Privacy Officer is responsible for receiving your privacy-related questions. You may send us your privacy-related questions or challenge our compliance with our Privacy Policy by submitting your concern to:

Northern Lights – Privacy Officer
249 Dufferin St, Toronto, Ontario, M6K 1Z5
privacyofficer@northernlightsto.ca

Information and Privacy Commissioner of Ontario
2 Bloor Street East
Suite 1400 
Toronto, ON M4W 1A8

Local: 416.326.3333
Long distance: 1.800.387.0073
TDD/TTY: 416.325.7539
Fax: 416.325.9195

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