Last Updated on 10/11/2023
This Privacy Policy explains how Pholoho Biotechnology Group (Canada) collects, uses, shares, and protects personal information, as well as the privacy rights and choices we offer, in connection with our websites, online services, and products and services (collectively, our “Services”). In this Privacy Policy, “Pholoho Biotechnology Group Inc. (Canada).”
Personal Information We Collect
Information You Provide Us. The personal information you may provide us includes:
• Contact details, such as your first and last name, the name of your organization, your email and postal addresses, and your phone number.
• Account data, such as the username and password you may use to create an online account with us.
• Communications we exchange with you, including when you contact us for questions, comments, or otherwise.
• Order and purchase history, including your interactions with our payment page.
• Payment details, such as your payment card number, bank account number, and shipping address. We rely on payment providers, such as Stripe, to process payments and do not have access to payment card numbers.
• Subscriber survey data, including information you provide when you respond to surveys and records of video or voice conversations with our marketing team.
• Marketing data, such as your preferences for receiving our marketing communications and details of 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 cooperatives, and licensors.
• Public sources, such as social media platforms.
• Marketing partners, such as companies that have entered into joint marketing relationships with us.
Automated Data Collection. We, our service providers, and our business partners may automatically record information about you, your computer or mobile device, and your interaction over time with our websites, online services, and communications, such as:
• Device data, such as the type and version of your computer or mobile device operating system, the manufacturer and model, browser type, screen resolution, RAM and disk size, processor usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device operator, radio/network information (e.g., WiFi, LTE, 3G, 5G) and general location information such as city, state, or geographic area.
• Online activity data, such as the pages or screens you viewed, the time you spent on a page or screen, the website you visited before navigating to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, access duration, and whether you opened our marketing emails or clicked on links they contain.
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 efficiently between pages, remembering your preferences, enabling features, helping us understand user activity and patterns, and facilitating online advertising.
• Local storage technologies, such as HTML5, which provide functionalities equivalent to cookies but can store larger amounts of data, including on your device outside your browser, in connection with specific applications.
• Web beacons, also known as invisible pixels or clear GIFs, which are used to demonstrate that a webpage or email has been viewed or opened, or that certain content has been viewed or clicked on.
How We Use Personal Information
We use personal information for the following purposes:
Provision of Services. We use personal information to fulfill our contractual obligation under our terms of use, including to:
• Provide, operate and improve our Services and our activities;
• Process your payments and carry out transactions with you; And
• Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.
Improve, monitor, personalize and protect our Services. It is in our legitimate business interest to improve and keep our Services safe for our users, which includes:
• Understand your needs and interests, and personalize your experience with the Services and our communications;
• Participate in surveys and record our video and audio conversations with consumers;
• Troubleshooting, testing and research to ensure the security of services; And
• investigate and protect against fraudulent, harmful, unauthorized or illegal activities.
Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve our Services and business. In connection with these activities, we may create aggregated, de-identified or other anonymous data from the personal information we collect. We transform 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 legitimate 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 personal information for the following marketing and advertising purposes:
• Direct sale. We may send you direct marketing communications relating to PholohoTM products to the extent permitted by law, including by email. You can opt out of our marketing communications as described in the Opting Out of Marketing section.
• Interest-based advertising. We may engage third party advertising companies and social media companies to display advertisements on our websites and other online services. These companies may use cookies and similar technologies to collect information about your interactions (including data described in the “Automatic Data Collection” section) over time on our Services, and use that information to serve advertisements. line that they think might be of interest to 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.
Unless consent is required, we undertake this marketing and advertising based on our legitimate business interest. Where we ask for your consent, you can withdraw it at any time.
Compliance and protection. We may use personal information to comply with legal obligations and to defend against legal claims or disputes, including:
• Protect our rights, privacy, safety or property or that of others (including making and defending legal claims);
• Verify compliance of our internal processes with legal and contractual requirements and internal policies;
• Apply the general conditions that govern our Services;
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activities, including cyberattacks and identity theft; And
• comply with applicable laws, legal requests and legal processes, such as to respond to subpoenas or requests from government authorities.
How we share personal information
We may share personal information with:
Affiliates. Within Pholoho Biotechnology Group for purposes consistent with this Privacy Policy
Suppliers. 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 services website analytics).
Payment processors. When you make a purchase on Pholoho.com, your payment card information is collected and processed directly by our payment processors, such as Stripe. We do not record or store payment card or bank account details. These payment processors may use your payment information in accordance with their privacy policies. Stripe’s privacy policy available at https://stripe.com/privacy.
Other social networking services. You may have the ability to access or register for the Services using your username and passwords provided by Facebook and other social networking sites (each, an “SNS”), or you may have there possibility of connecting an SRS account. In doing so, you authorize us to access and store information from the SNS – including, without limitation, your name, email address, date of birth, gender, current city, profile picture and URL – and to use and disclose them in accordance with this privacy policy. To control what information is shared with us, please review your privacy settings on each SNS and make the appropriate changes.
Third party. Third parties, such as advertising companies, data providers and data cooperatives for interest-based advertising and other marketing purposes, including for their own purposes. To learn how to unsubscribe, please see the “Privacy Rights and Choices” section below.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary as part of the professional services they provide to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we in good faith believe are necessary or appropriate for the compliance and protection purposes described above.
Beneficiaries of a transferred company. Purchasers and other relevant participants in business transactions (or negotiations for such transactions) involving a divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or part of the business or assets of Pholoho Biotechnology Group (including, in connection with bankruptcy or similar proceedings).
Google reCAPTCHA. To protect our website and other features, we use Google reCAPTCHA provided by Google Inc. (“reCAPTCHA”) for all visitors from the United States. We use reCAPTCHA to check whether data is entered into our forms by a person or by an automated program, script or bot. reCAPTCHA analyzes the behavior of the person entering the data using various features. This analysis starts automatically upon access to the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, browser type, settings and plug-ins, URL of the referring website, time spent on the respective website, movements mouse, input characteristics of data entry, including speed, sequence and selection of inputs, etc.). The data collected during the analysis is transmitted to a Google server, where it is stored and evaluated. Your use of reCAPTCHA is subject to the Google Privacy Policy and Terms of Service. For more information about reCAPTCHA, please visit: https://www.google.com/recaptcha/about/.
Please keep in mind that whenever you voluntarily make your personal information available to third parties or the public on or through our Services, that information may be viewed, collected and used by others. We are not responsible for the use of this information by others.
Privacy Rights and Choice
Account choice. If you have a Pholoho account, you can view 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.
Opting out of marketing communications. You can unsubscribe from marketing emails by following the unsubscribe 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.
Requests for personal information. We also offer you choices that affect how we treat the personal information we control. Depending on your location and the nature of your interactions with our Services, you may request the following with respect to personal information:
• Information about how we collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information we have collected about you. Where applicable, we will provide the information in a portable, machine-readable and easily usable format.
• Correction of inaccurate or outdated personal information.
• Deletion of personal information that we no longer need to provide the Services or for other legal purposes.
• Additional rights, such as to object and request that we limit our use of personal information.
To make a request, please write to us as indicated in the “How to Contact Us” section below. We may ask you for specific information to help us confirm your identity. You have the right to exercise the rights described above without discrimination.
Depending on your jurisdiction, you may designate an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority in accordance with applicable laws.
Additionally, you can limit the use of tracking technologies, such as cookies, by following the instructions in the “Opting out of online tracking” section below.
Limits to your choices. In some cases, your choices may be limited, for example where responding to your request would adversely affect the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and assert our legal rights. If you are not satisfied with the way we process your request, you can file a complaint by contacting us as indicated in the “How to Contact Us” section below.
Do not follow. Some Internet browsers may be configured to send “Do Not Track” signals to online services that you visit. We do not currently respond to “Do Not Track” or similar signals. To learn more about “Do Not Track,” please visit www.allaboutdnt.com.
Opting out of online tracking. 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 allow you to delete or refuse 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 www.allaboutcookies.org.
• Blocking the use of the advertising ID in your mobile settings. Your mobile device settings may provide features to limit the use of the advertising identifier associated with your mobile device for interest-based advertising.
• Use of privacy plug-ins or browsers. You can prevent our websites from setting cookies used for interest-based advertising by using a browser with privacy features, such as Brave, or by installing browser plug-ins such as Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies/trackers. You can also deactivate Google Analytics by downloading and installing the browser plug-in available at the following address: https://tools.google.com/dlpage/gaoptout.
• Platform unsubscriptions. The following advertising partners offer opt-out features that allow you to opt-out of the use of your information for interest-based advertising:
• Updating your SNS settings. To stop sharing your information with Facebook and other social networks with which Pholoho allows you to connect your account, please change your privacy settings on these platforms.
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 each browser and device you use.
Other sites and services
Our Services may contain links to websites and other online services operated by third parties. Additionally, our content may be embedded in web pages or other online services that are not associated with us. These links and embeds are not an endorsement or representation that we are affiliated with any third party. We do not control the websites or online services operated by third parties, and we are not responsible for their actions.
Security
We use a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are built in and we cannot guarantee the security of personal information.
International data transfer
You may provide personal information directly on our website in the United States. We may also transfer personal information from Europe to our affiliates and service providers in the United States and other jurisdictions. Please note that these jurisdictions may not provide the same protections as the data protection laws in your home country.
Where we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to ensure adequate protection of personal information and we will comply with applicable data protection laws, in particular relying on an adequacy decision from the European Commission or the UK Government or contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as indicated in the “How to Contact Us” section below.
Data Privacy Framework
Pholoho Biotechnology complies with the Canada-EU-US Data Privacy Framework, the UK Extension of the EU-US Data Privacy Framework and the Swiss-US Framework. Data Privacy Framework (collectively, the “Data Privacy Framework”) as set forth by the United States Department of Commerce regarding the collection, use, and retention of transferred personal information.
Pholoho Biotechnology Group may transfer personal information to third parties as described in this Privacy Policy. Pholoho Biotechnology Group maintains contracts with its third-party service providers limiting their access, use and disclosure of personal information in accordance with our data privacy framework obligations. Pholoho Biotechnology Group may be held liable if these third parties fail to comply with these obligations and we are responsible for the event giving rise to the damage.
Children
Our Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through our Services from a child under 16 without the consent of the child’s parent or guardian, as required by law, we will delete it.
Jobseekers
When you visit the “Careers” section of our websites, we collect the information you provide to us as part of your job application. This includes professional and personal contact information, professional credentials and skills, educational and employment 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, for example 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 improve the administration of our websites and, as necessary (a) to comply with applicable laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our rights or property or those of others; (c) in the context of a judicial investigation; and/or (d) to investigate or help prevent any violation or potential violation of the law, this Privacy Policy or our Terms and Conditions.
WHAT PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
Media
If you upload images to the Website, avoid uploading images that contain embedded location data (EXIF GPS). Website visitors can download and extract all location data from images on the site.
CONTACT FORMS
Cookies
If you leave a comment on our site you may choose to save your name, email address and website in cookies. These are for your convenience so you do not have to fill in your details again when you leave another comment. These cookies will last for a year.
If you have an account and log in to this site, we will set a temporary cookie to determine whether your browser accepts cookies. This cookie does not contain any personal data and is deleted when you close your browser.
When you log in, we will also configure several cookies to save your login information and your screen display choices. Login cookies last for two days and screen cookies last for a year. If you select “Remember Me”, your ID will be retained for two weeks. If you log out of your account, login cookies will be deleted.
If you edit or publish an article, an additional cookie will be stored in your browser. This cookie does not contain any personal data and simply indicates the identifier of the article you have just modified. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves exactly the same as if the visitor had visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website .
Analytics
This site uses Google Analytics, a program that provides important statistics on the number of visitors, pages viewed, traffic sources and other essential information to improve this site for users. These statistics are anonymous and cannot be linked to a specific person or user. “Behavioral targeting” is not used to allow you to see special content based on your clicking behavior; your surfing habits remain completely anonymous. Contact form data is never processed or stored in Analytics.
Google Analytics uses a cookie, which is a small file stored on your computer. We have configured Google Analytics in accordance with privacy legislation, so that no prior user authorization is required.
Who do we share your data with?
Pholoho Biotechnology Group does not share any of your data with third parties. Any information you may provide via our contact form or email address will only be seen and processed by employees of Pholoho Biotechnology Group.
How long do we keep your data?
If you leave a comment, the comment and its metadata are retained indefinitely. This allows us to automatically recognize and approve all follow-up comments instead of holding them in a moderation queue.
For users who register on our website (if applicable), we also store the personal information they provide in their user profile. All users can view, edit or delete their personal information at any time (except they cannot change their username). Website administrators can also view and edit this information.
Data collected for use in Google Analytics will be retained for 26 months by default.
What rights you have over your data
If you have an account on this site or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include data that we are obliged to retain for administrative, legal or security purposes.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
EXTERNAL LINKS
Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text/banner/image links to other websites, similar to https://www.poloho.com/.) The owners of this website cannot guarantee or verify the content of the websites containing external links, despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
International data transfer
You may provide personal information directly on our website in the United States. We may also transfer personal information from Europe to our affiliates and service providers in the United States and other jurisdictions. Please note that these jurisdictions may not provide the same protections as the data protection laws in your home country.
Where we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to ensure protection personal information and we will comply with applicable data protection laws,
SOCIAL MEDIA PLATFORMS
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms of use and privacy policies held with each social media platform respectively. . Users are advised to use social media platforms wisely and communicate and engage with them with due care regarding their privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive information to contact them through primary communication channels such as by telephone or email. ‘E-mail. This website may use social sharing buttons which allow web content to be shared directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your account. social media platform.
Shortened links in social media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default, some social media platforms shorten long URLs. Users are advised to take reasonable care and discretion before clicking any shortened urls published on social media platforms by this website and its owners. Despite best efforts to ensure that only real URLs are published, many social media platforms are prone to spam and hacking. Therefore, this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Retention of personal information
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (the optionally).
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, purposes for which we use personal information and whether we can achieve those purposes through other means, as well as applicable legal and regulatory requirements.
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 and online services. If required by law, we will also notify you of changes in another way that we reasonably believe will reach you, such as by email or otherwise through our Services. Any changes to this Privacy Policy will be effective when we post the amended version (or as indicated at the time of posting). In any case, 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
Pholoho Biotechnology Group Inc. is the entity responsible for processing personal information and is the data controller with respect to such processing. You can reach us by email at admin@pholoho.com or at the following postal addresses:
Pholoho Biotechnology Group, Inc. Headquarters
348 Main Street
Shediac, New Brunswick,
Canada E4P2E8