Privacy Policy

Effective Date: Oct. 13, 2016
This Privacy Policy is incorporated by reference into the Wellness Services Terms of Use. The Wellness Services are provided to and operated for Loblaws Inc. in Canada and powered by higi SH llc (“Higi”). The term “Loblaw”, “Higi,” “we,” and “us” includes Loblaws Inc. and its affiliates, subsidiaries and licensors including Higi and its affiliates and subsidiaries. The Privacy Policy explains how we may:
• collect,
• use, and
• disclose
information we obtain through the “Wellness Services.”

The “Wellness Services” means any websites, mobile applications, and other services under the control of Loblaw, whether partial or otherwise, in connection with providing an online or digital platform for provision of the Wellness Services, including www.yourwellnessstation.ca and Wellness station kiosks (the “Wellness Stations”). The Wellness Services provide a platform that gives you the ability to store and track your own personal information, including certain health-related information.
“Personal Information” means information pertaining to identifiable information, such as: name, address, email address, or phone number, as well as any other information, including Body Measurements, which can identify you as an individual. Information that is anonymized or aggregated and cannot be associated with an identifiable individual is not considered to be Personal Information..
“Body Measurements” means statistics, such as weight, Body Mass Index (BMI), blood pressure and pulse measurements, and other similar information, that we collect about you when you use the Wellness Services. Body Measurements which is not combined with Personal Information or which do not pertain to an identifiable individual are not considered to be Personal Information.
"Your User Content" means the information that you may post, submit, upload, publish, display, transmit, or otherwise share through the Wellness Services, including but not limited to data, text, files, software, sound, photos, videos, graphics, artwork, ideas, opinions, status updates, comments, and “likes.”

THE WELLNESS SERVICES COLLECT YOUR INFORMATION
We and third parties that provide functionality on the Wellness Services collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Wellness Services. This information may be used to improve the quality of the Wellness Services, provide personalized services and relevant advertisements and for other purposes detailed in this Privacy Policy.
Personal Information Collection. When you register to use the Wellness Services (a “Registered User”), you may provide Personal Information, such as your name, email address, postal code, gender, and birthday. You may also provide other optional profile information such as your profile photo and your postal address.
Social Media Connection. We collect Personal Information from social media websites, such as Facebook or Twitter, when you connect to your Wellness Servicesaccount using your social media account. For example, when you log in with your Facebook credentials, we may collect Personal Information from Facebook, such as your email address, profile picture, and friend list.
Using the Wellness Services. We collect information from you as you use the Wellness Services. For example, we collect the Body Measurements generated from your use of a Wellness Station and the location of that Wellness Station for information system purposes and to allow us to manage internal resources. You may also be able to post photographs to your activity feed.
Customer Support. We may collect Personal Information through your communications with our customer-support team.
Location Information from Your Mobile Device. We may collect and store your location information if you enable your mobile device to send it to us. Collection of this information may improve the provision of the Wellness Services. For example, we can help you find the nearest Wellness Station.
Cookies, Automatic Data Collection, and Related Technologies. When you visit the Wellness Services, we and third parties that provide certain functionality on the Wellness Services, such as Facebook, Twitter, Google, and ad networks may engage, receive and record information from Wellness Stations and server logs from your browser, including your IP address, and from cookies and similar technology. This information is used to improve the quality of the Wellness Services, such as to store your preferences, customize the Wellness Services, and provide more relevant advertising. We will not use or share individualized Body Measurements or any other health or sensitive information for use in advertising and personalization outside of the Wellness Services without your permission.
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Wellness Services may not work properly.

By using the Wellness Services, you are authorizing us to gather, parse, and retain data related to the provision of the Wellness Services in accordance with this Privacy Policy.

HOW WE USE YOUR INFORMATION

We may use information for marketing purposes, but we will not rent, sell, or share Personal Information for third parties to directly market to you, unless we obtain your consent.
We may use anonymous and aggregate information for any purpose, including for marketing purposes.
Internal and Service-Related Usage. We use information, including Personal Information, for internal and service-related purposes only and may provide it to third parties to allow us to facilitate the Wellness Services. We may use and retain any data we collect to provide and improve or personalize our services.
Your User Content Posted to the Wellness Services. You may post Your User Content to the Wellness Services to document your lifestyle, interact with other users, and for us to provide information about the content you post. For example, you may post a photo of a meal you ate, a log of the physical activities you performed, and the friends you were around. When you post Your User Content, our employees and service providers may review them to categorize and add information about them. Your User Content will be publicly available, so do not post any information that you want to keep private.
Communications. We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.
Marketing. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, except in accordance with this Privacy Policy or unless we have your permission. We also do not provide any Personal Information to any third-party ad networks, except in accordance with this Privacy Policy. We also may use your Personal Information and other information to communicate with you by email or text message to provide you with information we think may be of interest to you, at all times in compliance with the Canadian anti-spam legislation. We will send you text messages only with your consent.You may opt out of our marketing electronic communications by using the opt-out link in an email and you may turn off or unsubscribe from text messages by texting STOP in reply to marketing text messages. Please note that even if you opt-out of marketing communications, we may still need to contact you with important information about your account and our Wellness Services.

To support the Wellness Services, which we provide at no cost to you, we may use non sensitive Personal Information and data collected through cookies and similar technology to deliver Loblaw and third-party interest-based advertising to you on and off the Wellness Services. We will obtain your permission before we provide individualized Body Measurement data or sensitive Personal Information to third-party ad networks to deliver third-party interest-based advertising outside of the Wellness Services. Please note, and you agree through use of the Wellness Services, that we may personalize your experience, including by showing you advertising, on the Wellness Services using data we learn about you. You may at any time change your preferences related to the use of your Personal Information for advertising purposes on other websites and services by visiting our Privacy Preferences web page.

Aggregate Data. We may anonymize and aggregate data collected through the Wellness Services and use it for any purpose. Such information does not identify you individually.
WE MAY DISCLOSE YOUR INFORMATION
We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, except as detailed in this Privacy Policy or unless we have your permission. We may share anonymous Body Measurements and other non Personal Information with third parties for marketing purposes.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Wellness Services.
Displaying to Other Users. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. The content you post to the Wellness Services may be displayed on the Wellness Services to other users. Other users of the Wellness Services also may be able to see some information about you that you have included in your profile, such as your first name, the first initial of your last name, city, province/territory, and profile photo. When you choose to share Body Measurement information this information may be accessible to other users. We are not responsible for privacy practices of the other users who will view and use the posted information.
Social Networking and Other Website Services. The Wellness Services may allow you to share information, including Personal Information, with third-party services and social networking websites, such as Facebook and Twitter. We do not share your Personal Information with them unless you direct the Wellness Services to share it. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
We may also disclose your Personal Information with your permission.SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.
By using the Wellness Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Wellness Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Wellness Station and/or through the Wellness Services or sending an email to you if you are a Registered User.

CHILDREN’S PRIVACY
We do not knowingly collect, maintain, or use Personal Information from children, and no part of the WellnessServices is directed to children. If you learn that your child has provided us with Personal Information without your consent, you may alert us at loblawprivacy@loblaw.ca. If we learn that we have collected any Personal Information from childrenwithout their parental consent, we will promptly take steps to delete such information and terminate the child’s account.

USERS

. By visiting or using the Wellness Services and providing your information, you undertand that your Personal Information may be transferred, processed and stored outside Canada, and therefore may be available to government authorities under lawful orders and laws applicable there.

ACCESS AND UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you have any questions or concerns about this Privacy Policy or the use of your information, or to access, modify or update any information we have received, please contact loblawprivacy@loblaw.ca. If you are a Registered User, you can log into your account at any time to access and update the information you have provided to us.

Data Retention. We will retain your information for as long as your account is active or as needed to provide you the Wellness Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Account Deactivation and Deletion. If you no longer desire to use the Wellness Services, you may deactivate or delete your account by sending us an email to support@higi.com. Deactivating your account puts your account on hold and is the same as you telling us not to delete any information because you might want to reactivate your account at some point in the future. When you delete an account, you are requesting that your account and the information stored therein be permanently deleted from the Wellness Services. You should only delete your account if you are sure you never want to reactivate it. Please note, certain data you have provided may continue to exist in aggregate form that cannot be used to identify you.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES
Posting of Revised Privacy Policy. We may update this Privacy Policy to reflect changes to our information practices. If you are a Registered User and we make any change in how we use Personal Information we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Wellness Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Loblaws Inc.

1 President’s Choice Circle

Brampton, ON L6Y 5S5