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Privacy & Security


Gluten Free Wholesale Inc. is committed to maintaining the confidentiality of information that has been provided to us by our users and others. This Privacy Policy has been prepared to confirm such commitment and to assist you in understanding the type of Personal Information that we may collect from you and from others, how we may use that Personal Information, to whom we may disclose it, and how we safeguard that Personal Information and your privacy. We are committed to collecting, using and disclosing Personal Information in a responsible manner, and only to the extent necessary for the services we provide. This Privacy Policy has been developed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”). 



COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION 



Personal Information means information about an identifiable individual. Personal Information would include such things as a person’s home address and telephone number, e-mail address, age, gender, race, height and weight, and other medical information, income and activities. Personal Information does not include certain business information, specifically, a person’s title at work, business address and business telephone number. 



Gluten Free Wholesale Inc. collects, uses and discloses Personal Information as required to provide our users with the services more fully described on the Gluten Free Wholesale Inc.  website (the “Services”) which allow access to reviews of vendor’s services to the pharmaceutical industry. If we wish to collect Personal Information from you, we will inform you before gathering the information, and will explain to you how we intend to use the information. The Personal Information that we typically collect includes contact information (addresses, telephone numbers, facsimile numbers and e-mail addresses). We collect this Personal Information in order to enable the exchange of documents and/or information through our website. We may collect this information directly from you or from third parties (who may be used to confirm that our clients are licensed physicians). 



In certain circumstances, PIPEDA provides that we may disclose your Personal Information without your consent. Such circumstances include: where required by law or by order of a court or tribunal; where the information is used for the purpose of collecting a debt owed to Gluten Free Wholesale Inc.; where the Personal Information is requested by a government institution to enforce any law; where we believe that the Personal Information relates to a breach of an agreement (including, without limitation, the Gluten Free Wholesale Inc Terms and Conditions) or a contravention of the laws of Canada or a Province that has been, is being or is about to be committed; and in the case of an emergency that threatens the life, health or security of an individual. In such circumstances, we will not disclose more information than is reasonably necessary. 



In the event Gluten Free Wholesale Inc. goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, Gluten Free Wholesale Inc. users, and therefore their personal information will, in most instances, be part of the assets transferred. If as a result of a business transition, the users’ personally information will be used in a manner different from that stated at the time of collection, they will be given a choice not to have their information used in this different manner. We are committed to protecting your privacy. 



We will not sell, trade or exchange any Personal Information that we collect. We will collect e-mail and mailing addresses in order to send you electronic communications on a regular or semi-regular basis. You may sign up for these electronic communications when you register to use the Gluten Free Wholesale Inc Services. We use e-mail in order to verify account information, update you on features, products or offers related to the Services or third-party services, make service announcements, and address your customer service requests. Gluten Free Wholesale Inc occasionally conducts voluntary surveys, which collect contact information and demographic information in addition to your survey responses. We use this information in order to monitor and improve the Services. We may share demographic information with a partner or advertiser, but we aggregate such data so that your information is not personally identifiable. 



SPAM POLICY 



Gluten Free Wholesale Inc does not permit users to abuse the Services by sending unsolicited commercial faxes or by placing an unreasonable or disproportionate strain on the system. Gluten Free Wholesale Inc reserves the right to employ any available means to prevent “junk faxes”. Please refer to the Terms of Use found on such website and in particular to the sections entitled “Use of Site” and “Restrictions”. 



SECURITY OF YOUR INFORMATION 



Gluten Free Wholesale Inc  takes all reasonable precautions to safeguard your Personal Information, whether the information is kept electronically or otherwise. This involves ensuring that the only persons who view your Personal Information are those who reasonably have the need to do so, and that where necessary and appropriate, sensitive Personal Information may be locked in filing cabinets or in offices. All of our firm members are trained to collect, use and disclose Personal Information only as necessary to serve our clients’ needs and in accordance with this Privacy Policy. Electronically, all of our computers and our computer network may only be accessed with passwords which are updated regularly. Further, our computer system employs industry standard encryption methods to prevent unauthorized access to customer documents and account information stored on our servers. Gluten Free Wholesale Inc also protects information with the HTTPS security protocol during transmission to your web browser. Of course, we cannot protect any information after it has left our website. Gluten Free Wholesale Inc is end-to-end secure. Since they are not needed, salt values are not associated with any documents and e-signatures are not key-coded or associated with digital certificate information. Gluten Free Wholesale Inc is committed to our Services being secure. 



ACCESSING YOUR PERSONAL INFORMATION 



With very limited exceptions as set forth in PIPEDA, you are always entitled to access the Personal Information that we have collected from you. We reserve our right to charge you a nominal fee to provide you with such access. If we cannot provide you with access to your Personal Information, we will advise you that that is the case within 30 days, and will tell you, if possible, why we cannot provide you with such access. 



If you believe that any factual information contained in your Personal Information is incorrect, please advise us so that we can update our records. We may ask you to provide evidence that our files are incorrect. If we do not agree that the Personal Information is incorrect, we will include in our file a note from you that you believe the Personal Information to be incorrect and we will forward such note with the Personal Information if it is sent to third parties. 



TESTIMONIALS 



When posting testimonials at www.gfwholesale.ca  any personal information that is submitted can be read, collected, or used by other users of that website, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit on such website. 



LOG INFORMATION 



Gluten Free Wholesale Inc servers track usage of the Services through log files. We use this information in order to analyze trends and gather aggregate demographic information (including IP addresses, browser type) that is not personally identifiable. 



USE OF COOKIES 



A “cookie” is a small data file that contains information related to your usage of the Services. You do not need to enable cookies to use Gluten Free Wholesale Inc. However, allowing them will improve the user experience. We use cookies to track, target and better understand how you use the Services, and to maintain, analyze and improve the overall quality of the Services. Gluten Free Wholesale Inc uses both session cookies, which do not persist after you close the browser, and persistent cookies, which are stored on your computer’s hard drive. We do not link the information we store in cookies to any personally identifiable information you submit while on our website. 



PROFILE 



Gluten Free Wholesale Inc stores the information collected through log files and cookies in a profile containing each user’s viewing preferences. We use this information in order to identify your interests and improve the content provided by the Services. 



THIRD PARTY CONTENT 



Gluten Free Wholesale Inc may provide information regarding usage of our website (such as the number of times users view advertisements) to third party advertising partners. The information we share with third party advertisers is not personally identifiable. 



LINKS 



Our website may from time to time contain links to other websites that may collect your Personal Information. Gluten Free Wholesale Inc does not assume any responsibility for their privacy practices or policies, and cannot be held liable for the actions of those third parties. You should review the privacy policies of such parties before providing them with any Personal Information. 



RETENTION OF INFORMATION 



All Personal Information will be disposed of when it is no longer required to be maintained. It will be disposed of in a manner that is secure and which respects your privacy. When we dispose of client information, including Personal Information, our paper files are shredded and information kept electronically is deleted from our computers and computer network. When we dispose of old computer equipment, we ensure that all information, including Personal Information, is “wiped clean” from such equipment before it is disposed of. 



QUESTIONS AND CONCERNS 



If you have any questions or concerns with respect to our privacy practices, please do not hesitate to contact our Privacy Officer at: 



info@gfwholesale.ca 



He/She will endeavour to answer your questions or concerns as quickly and completely as possible. 



If you wish to make a formal complaint about our privacy practices, please forward your complaint in writing to our Privacy Officer. He will acknowledge receipt of your complaint and ensure that the matter is investigated promptly





If you have a general inquiry about privacy legislation, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for disputes relating to the privacy legislation. You can contact the Information and Privacy Commissioner at: 



112 Kent Street 

Ottawa, Ontario 

K1A 1H3 

Phone: 1 (800) 282-1376 

Fax: (613) 947-6850 

Email: info@privcom.gc.ca 

www.privcom.gc.ca 

 



Gluten Free Wholesale Inc. reserves the right to amend this Privacy Policy at any time and from time to time and we encourage you to refer back to this Privacy Policy regularly. Any amendment to this Privacy Policy will apply to the Personal Information collected, used or disclosed from and after the date of such amendment. 



Last updated: June, 2013.