Updated: August 3, 2020
As an online and mail-order retailer, we collect consumers’ personal information such as their names, addresses, and other contact information to process orders for our products, publicize our business activities and product offerings, and generally communicate with our customers. We rely on a payment processor to accept and process payment card information. When individuals visit our website, we collect data to understand how visitors use our site. And we utilize the support of services providers to market our products. Nearly all of our service providers use information we provide to them solely for the purpose of supporting our business and for no other purpose, but a small number may utilize data to develop and refine the services and tools that they provide to us.
1. Policy Scope
We understand and use the term “Personal Information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. The Vital Choice website is an eCommerce website. By using the Vital Choice website, you consent to the data practices described in this Policy and direct us to collect and use your Personal Information in accordance with this Policy.
This Policy applies only to our Services. Although we might link to third-party websites (for example, Facebook, Instagram, or Twitter), software, or services, this Policy applies only to our Services. Please refer to the privacy policies on any third-party websites, software, or services to learn how they use your personal information. We encourage you to read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. We understand your use of our Services to mean that you accept and consent to the use of your Personal Information as described in this Policy.
TRUSTe Privacy Program – As noted in our summary, the twin principles of respect and protection of our customers’ privacy are integral to our business mission. To foster these values within our company, we are a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. Because we want to demonstrate our commitment to your privacy, we have agreed to disclose our information practices and have our privacy practices reviewed for compliance by TRUSTe.
If you have questions or concerns regarding this Policy, you should first contact us at firstname.lastname@example.org. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe here. TRUSTe may serve as a liaison with us to resolve your concerns.
2. Categories of Personal Information We Collect
Broadly speaking, we collect two broad types of Personal Information: (a) User Information and (b) Usage Information. Below is an explanation of the particular categories of Personal Information we collect within each type, including information collected in the last 12 months.
“User Information” refers to information collected about users of the Services.
If you place an order with us, either through our website or over the telephone, we will collect your name, billing and/or shipping address, email address, and telephone number. If you place an order to be delivered to someone else, we also will collect this information about the recipient of your order. You will have the option to register as a customer and establish a customer account that you can use to store your Personal Information, order history, and preferences for faster order checkout. You might be assigned a Vital Choice Customer Identification Number, and we might collect that information as well. Your billing and payment card information will be directly entered into our payment card processor’s database, which uses security controls and mechanisms to safeguard your card information.
If you contact us through our website, send an email or fax to us, or provide us feedback in writing or on the telephone, we will collect your name, email address and/or telephone/fax number, and whatever other information you provide to us. Telephone calls to our company may be recorded. If you respond to customer surveys, we may collect demographic information that may or may not be linked to you directly, such as age or date of birth and gender.
“Usage Information” refers to information about your computer hardware and software and your interaction with our website (e.g., duration of site visit and pages and products viewed) that we may automatically collect when you use or interact with our website. Whenever you use our website, we will collect your IP address, browser type, domain names, access times and referring website addresses. In particular, we collect information about the manner in which our website is used, the devices on which they are used, and our website’s performance. This information is used for the operation of our Services, to maintain quality of the Services, and to provide general statistics regarding use of the Vital Choice website. Depending on your device or browser privacy settings, Usage Information can include location data, such as geographic information regarding the location of the accessing device. If we combine Usage Information with User Information, we will treat the combined data as User Information.
3. How We Collect Personal Information
For customers who place online orders with us or establish customer accounts, we collect your information through our interactive webforms or through customer service representatives on the telephone.
For individuals who contact us through our website, email, fax, or on the telephone, we will collect whatever information you provide through the medium you use to communicate with us.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page.
For example, if you personalize Vital Choice pages, or register with the Vital Choice site or services, a cookie helps Vital Choice to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Vital Choice website, the information you previously provided can be retrieved, so you can easily use the Vital Choice features that you customized.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Vital Choice services or websites you visit. We use the information cookies and web beacons to collect and statistically monitor how many people are using our Services or opening our emails.
Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information. To completely “opt out” of the collection of any information through cookies or other tracking technology, you must manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want may be difficult. For example, not all tracking technologies can be controlled by browsers, and unique aspects of your browser might be recognizable even if you disable a tracking technology. In addition, not all settings will necessarily last or be effective, and even if a setting is effective for one purpose, data still may be collected for another. Even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.
As explained below in Section 5, similar to many eCommerce businesses, we partner with Facebook to provide announcements and advertisements about Vital Choice promotions, sales, new products, and other news to customers who are also active on Facebook and have chosen to receive such information through their Facebook accounts. We are able to provide this targeted information to Facebook users through a “pixel” that operates on our website. Facebook may use information collected through this pixel to refine and expand its service offerings. If you do not want your information collected through this pixel, you may adjust your browser settings to restrict this collection, but doing so may limit your ability to fully experience the interactive features of our website.
4. How We Use Personal Information
We use your Personal Information for a number of purposes that we believe to be consistent with your expectations when you interact with us and our Services, including:
• To process orders. We primarily use our customers’ personal information to receive and fulfill orders for our products. Your name, contact information, and payment card information is necessary for us to take your order and send purchased products to you.
• To otherwise provide Services and support. We use your Personal Information to provide and manage the Services, communicate with you about our Services, and fulfill any contractual obligations we otherwise have with you. In addition, we use your Personal Information to support your use of the Services and to ensure the quality and security of the Services. Information submitted with orders is used to manage customer accounts, generate receipts, confirm and fulfill orders, give notice regarding shipments, keep track of sales, and generally perform our obligations in connections with sales of items from our shop. If you elect to have your account login information remembered to speed up your shopping experience, your login information will be remembered as part of your Usage Information
• To communicate with you. If you contact us, we will use your email address and other information you provide to us to communicate with you. We may retain your contact information and copies of our communications with you for our records.
• To provide announcements and marketing. We may use your name and contact information to provide you with news about promotions, offerings, events, and other information about our business. From time to time, we may also conduct customer surveys. You may have the option of receiving emails, direct mail, SMS texts, voice messages, and/or newsletters directly from us. You may elect to opt-out of these communications by clicking an unsubscribe link, responding unsubscribe, or removing the checkmark beside the specific email type in your account, which will indicate that you do not want to receive these communications or to participate in these activities. In order to be removed from the catalog direct mail, please call or email customer service to request to be added to our do not mail list.
• Analytics. We may use information for analytics purposes and to operate, maintain, and improve the Services. We may also use information to create new products and services.
You may choose whether to receive interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. You can also optout of interest-based advertising within mobile apps based on advertising identifiers on your device (for example, through cross-app tracking). See the Advertising and Privacy options under your device’s Settings for more information. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out means only that those selected members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Vital Choice is not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, Vital Choice currently does not take action in response to these signals. For more information on “do-not-track,” visit http://www.allaboutdnt.com.
• To promote security and appropriate use. We hope everyone who uses our website will do so appropriately and with respect for our community. But, probably like you, we realize that not all online activity is beneficial. Therefore, we may need to use Personal Information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity relating to our Services and generally safeguard and maintain the security of our website and business.
• To meet legal requirements. We may be required to use or disclose your Personal Information when necessary to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
• Other purposes. We may use your information for any other legal, business, or marketing purposes that are compatible with this Policy.
5. How We Share Personal Information
Service Providers. Like most businesses, we rely on support from other businesses to provide our Services. Our payment processor and customer relationship management platform provider will have access to and process information of individuals who make purchases from our online shop. We may rely on a service provider for IT and security support and grant access to information collected as part of those services. We will transfer or share information with service providers only in accordance with applicable information privacy laws. Except as noted below with respect to Facebook and third party marketing partners, our service providers are authorized to use your information only as necessary to provide services to us and are not permitted to use your information for other purposes.
With respect to advertising and marketing, we share information collected from users with our marketing partners to facilitate delivery and distribution of information about Vital Choice. For example, we share names and contact information with digital marketing partners for distribution of our email newsletter and announcements to individuals who register to receive this information. We share similar information with the publisher and distributor of our paper catalog to individuals who sign up to receive our mailings.
As noted above, we partner with Facebook to provide announcements and advertisements about Vital Choice promotions, sales, new products, and other news to customers who are also active on Facebook and have chosen to receive such information through their Facebook accounts. We are able to provide this targeted information to Facebook users through a pixel that Facebook operates on our website. Facebook may use information collected through this pixel to refine and expand its service offerings. If you do not want your information collected through this pixel, you may adjust your browser settings to restrict this collection, but doing so may limit your ability to fully experience the interactive features of our website. We also share data with third party marketing partners for commercial purposes.
Legal Requirements. We may be required to use or discloses your personal information when necessary to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
Publicly Posted Content. If you post comments, images, and other content to a location that is public facing, including the app, our website, storage locations, or social media, your posted information will be publicly viewable.
With Your Consent. We may share some or all of your information with any other third party with your affirmative consent. For instance, we display personal testimonials of satisfied customers on our Websites in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
6. Right to Access Your Information
Under our Policy, you have a right to access the information we have collected during the last 12 months. Specifically, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising User Rights, below), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of other businesses or persons with whom we share that personal information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information for a business purpose, the Personal Information categories that each category of recipient obtained.
7. Right to Request Deletion
Under our Policy, you have the right to request that we delete any of your Personal Information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising User Rights, below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
8. Correcting and Updating Personal Information
You can always contact us in order to request that we change your Personal Information if you believe the Personal Information we have for you is incorrect. We will review your request but may be restricted in our ability to change your Personal Information
9. Exercising User Rights
To exercise the rights described above, please submit a verifiable consumer request to us by one of the following methods:
- Emailing us at firstname.lastname@example.org
- Calling us at 866-482-5887
- Submitting a request through our interactive webform with this button below: https://www.vitalchoice.com/content/contact-customer-service
Only you, or, if you are a California resident, a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability only twice within a 12-month period.
To verify the identity of an individual making a request, a two-step process will need to be completed. A verifiable consumer request must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Separately provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use Personal Information provided in a verifiable consumer request only to verify the requestor’s identity or authority to make the request.
10. Response Timing and Format
We will endeavor to provide an initial response to a verifiable user request within 10 days of receipt and will attempt to fulfill a verifiable user request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will cover only the 12-month period preceding our receipt of a verifiable user request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable user request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against anyone for exercising any of their rights under this Policy or any applicable information privacy or data protection law. Unless otherwise permitted, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
But if any part of our Services involves a financial transaction with you, we may offer you certain financial incentives permitted by applicable laws that can result in different prices, rates, or quality levels. Any financial incentive permitted under applicable law that we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. However, we do not currently provide any financial incentives.
12. Opt-Out & Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Vital Choice by contacting us here:
- Web page: https://www.vitalchoice.com/content/contact-customer-service
- Email: email@example.com
- Phone: 866-482-5887
13. Personal Information of Children Under 16
Vital Choice does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of 16, you must ask your parent or guardian for permission to use this website. If you think we have collected Personal Information from a child under 16 years of age for whom you are the parent or guardian, please contact us at the notice address provided below.
We maintain administrative, physical, and technical safeguards to reasonably and appropriately protect the confidentiality, availability, and integrity of your Personal Information. Vital Choice secures your personal information from unauthorized access, use, or disclosure. Vital Choice uses the following methods for this purpose:
- SSL Protocol
Verisign is an independent, third-party company engaged in the development of digital trust. Verisign provides authentication of Internet services, digital identity, and intellectual property. By clicking on the Verisign logo, the Verisign website will serve up a web page that confirms that Vital Choice Wild Seafood & Organics, SPC is "Verisign Authenticated."
When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
Our employees receive training on our security practices and obligations. While we strive to safeguard your Personal Information, we cannot completely ensure the privacy of certain communications such as email to and from us because they are not encrypted.
But given the nature of the Internet and the fact that network security measures are not infallible, we cannot guarantee the security of your Personal Information. In the event we become aware of a data security breach, we will provide you with notice as required by applicable federal, provincial, and state laws.
15. Changes to Our Policy
If we change this Policy, we will post the updated Policy and its effective date on our website, and such updates will be accessible through our website.
15. Contact Information – Questions, Accessing, Correcting and Updating your Personal Information, Direct Marketing
Please contact us using the contact information listed below if you:
- Wish to make a complaint about our activities;
- Would like to access your Personal Information held by us;
- Would like to opt- out of direct marketing; or
- Would like to correct your Personal Information held by us,
We will promptly investigate and respond.
Vital Choice Wild Seafood & Organics, SPC
Attn: Privacy Inquiry
2460 Salashan Loop
Ferndale, Washington 98248