This Privacy Policy explains how Jade Life Inc. (“Jade”, “we”) collects, uses, shares, and protects personal information, and the privacy rights and choices we offer, in connection with our websites (available at www.jadeforhealth.com), online services and products (collectively, our “Services”).

We provide additional information for California residents and individuals located in Europe below.

Personal Information We Collect

Information you provide to us. Personal information you may provide to us includes:

• Contact details, such as your first and last name, organization name, email and mailing addresses, and phone number.
• Account data, such as the username and password that you may use to establish an online account with us.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Order and purchase history, including your interactions with our checkout page.
• Payment details, such as your payment card number, bank account number and shipping address.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  
  

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Data providers, such as information services, data co-ops, and data licensors.
• Public sources, such as social media platforms.
• Marketing partners, such as companies that have entered into joint marketing relationships with us.
  
  

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, Services and our communications, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, province, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.
  
  

Cookies and similar technologies. Our Services may use the following technologies:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
  
  

How We Use Your Personal Information

We use your personal information for the following purposes:

Service delivery. We use your personal information to:

• Provide, operate and improve our Services and our business;
• Process your payments and complete transactions with you;
• Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
• Understand your needs and interests, and personalize your experience with the Services and our communications; and
• Provide support for our Services, and respond to your requests, questions, and feedback.
  
  

Research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising. We, our service providers, and our third party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you Jade-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the “Your Choices” section below.
• Interest-based advertising. We may engage third party advertising companies and social media companies to display ads on our websites and other Services. These companies may use cookies and similar technologies to collect information about your interactions (including the data described in the “Automatic data collection” section) over time across our Services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to them or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.

Compliance and protection. We may use your personal information to:

• Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce the terms and conditions that govern our Services; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  
  

Comply with law. We may use your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

Consent. With your consent, we may use your personal information for any other purpose not described above.

How We Use Your Personal Information

We may share your personal information with:

• Affiliates of Jade for purposes consistent with this Privacy Policy.
• Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).
• Payment processors. When you make a purchase at Jade, your payment card information is collected and processed directly by our payment processors, such as Stripe. We do not record or maintain payment card or bank account details. These payment processors may use your payment data in accordance with their privacy policies. Stripe’s privacy policy is available at https://stripe.com/privacy.
• Facebook and other Social Networking Services. You may be given the option to access or register for the Services through the use of your username and passwords provided by Facebook and other social networking sites (each, an “SNS”), or otherwise have the option to connect an SNS account. By doing so, you authorize us to access and store information from the SNS – including, without limitation, your name, email address(es), date of birth, gender, current city, profile picture and URL – and to use and disclose it in accordance with this Privacy Policy. To control what information is shared with us, please check your privacy settings on each SNS and make changes as appropriate.
• Third Parties. Third parties, such as advertising companies, data providers and data co-ops, for interest-based advertising and other marketing purposes, including those third parties’ own purposes.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. Acquirors and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Jade (including, in connection with a bankruptcy or similar proceedings).
  
  

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our Services, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

Your Choices

Access, correct or delete. If you have a Jade account, you can review and update certain account information by logging into your account. Registered users may also contact us to request deletion of their account and certain personal information. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to limit or decline access and deletion requests, such as where we need to retain your information for security, compliance, fraud prevention, and safety purposes, to comply with law, to establish or defend legal claims, to protect the identities and rights of other users, to protect trade secrets, or because access or deletion is not practicable. If we delete your account, you will not be able to access it. If we delete your information, it will generally be deleted from our active databases, and the information may remain for a period of time in our backup files and in unstructured files until these records are deleted in the ordinary course of business.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. You may continue to receive service-related and other non-marketing emails.

Online tracking opt-out. There are a number of ways to limit the tracking of your online activity and collection of device data through automated means, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Updating your SNS settings. To stop sharing your information with Facebook and other SNS with whom Jade permits you to connect your account, please modify your privacy settings on those platforms.
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites: optout.aboutads.info
  • Digital Advertising Alliance for Mobile Apps: www.youradchoices.com/appchoices
  • Network Advertising Initiative: optout.networkadvertising.org/
  • Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.
    
    

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

International Data Transfer

We are headquartered in Canada and it is necessary for us to process personal information in Canada, the U.S. and other countries to provide our Services.

Children

Our Services are not intended for use by children under 19 years of age. If we learn that we have collected personal information through our Services from a child under 19 without the consent of the child’s parent or guardian as required by law, we will delete it.

Job Applicants

When you visit the “Careers” portion of our websites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and to respond to surveys.  We may also use this information to provide improved administration of our websites, and as otherwise necessary (a) to comply with applicable laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of applicable laws, this Privacy Policy, or any other Jade policy.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our websites. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

You can reach us by email at hello@jadeforhealth.com or at the following postal addresses:

Jade Liquid Clarity
Suite # 258 
551 Lakeshore Rd E. 
Mississauga Ontario L5G 0A8
hello@jadeforhealth.com

Information for California Residents

We are providing this supplemental privacy notice to California residents, pursuant to the California Consumer Privacy Act 2018 (“CCPA”).

The CCPA grants California residents the following rights:

• Our Privacy Policy describes how we use and share your personal information, including during the past 12 months. We describe the sources through which we collect personal information and the types of personal information collected in the “Personal Information We Collect” section above. We describe the purposes for which we use and share this information in the “How We Use Your Personal Information” section above and the “How We Share Your Personal Information” section above.
• You can request a copy of the personal information that we maintain about you.
• You can ask to delete the personal information that we maintain about you.
• Opt-out of the “sale” of your personal information. We do not monetize your personal information or sell it in the traditional sense. However, you can ask us to refrain from sharing your information with third parties to provide you with offers and promotions. In addition, you can limit the use of tracking technologies, such as cookies, by following instructions in the “Your Choices” section above.
  
  

Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.

You are entitled to exercise the rights described above free from discrimination.

Here is how you can submit requests:

• To request access to or deletion of personal information collected via our Services or to opt-out of the sharing of your information, please email us at hello@jadeforhealth.com.
• To learn how to limit tracking, please see the “Your Choices” section above.
• To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
• Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf.
  
  

Notice to Individuals Located in Europe

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. Jade Life Inc. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal basis for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the bullets below:

• Service delivery: Processing is necessary to perform the contract governing our provision of our Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request.
• Research and development, Marketing and advertising, Compliance and protection, Sharing your personal information as described in this Privacy Policy: These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Comply with law: Processing is necessary to comply with our legal obligations.
• With your consent: Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent.
  
  

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We ask you not to provide any sensitive personal information to us because we do not have the ability to identify or offer enhanced protections for sensitive personal information. If you choose to provide us with any sensitive personal information, we will process it as “personal information” in accordance with this Privacy Policy.

Your rights. Data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Provide you with information about our processing of your personal information and give you access to your personal information.
• Update or correct inaccuracies in your personal information.
• Delete your personal information.
• Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict the processing of your personal information.
• Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
  
  

You may submit these requests by email or our postal address provided above.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.

Data retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.