SomaLife's Personal Information
Privacy Policy

The purpose of this policy is to govern SomaLife’s collection, storage, use and disclosure of personal information in a manner which recognizes both the right of individuals to protect their personal information and the need of SomaLife to collect, store, use, and disclose personal information for purposes reasonably related to SomaLife’s operations.

SomaLife recognizes its obligation to maintain the confidentiality of its customer’s information. This policy has been developed with this obligation in mind.

2. COMPLIANCE

SomaLife shall designate a person (or persons) to be responsible for ensuring SomaLife’s compliance with the requirements of all applicable legislation (the “Personal Information Administrator(s)”) and shall make available the Personal Information Administrator’s position name, title and contact information upon request.

SomaLife shall develop and follow policies and practices that are necessary to ensure compliance with the legislation and will provide a process to respond to complaints that may arise relating to the operation of the legislation.

3. COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

Where practical, SomaLife endeavours to collect personal information directly from the person to whom the information pertains. When necessary, SomaLife will collect personal information from other sources.

By becoming a Distributor or a customer of SomaLife, an individual consents to SomaLife’s necessary collection, use or disclosure of the individual’s personal information in order to properly conduct it’s business.

SomaLife shall only collect, use or disclose personal information when the individual’s consent has been obtained or when the legislation allows the collection, use or disclosure without the individual’s consent, or when the legislation deems the consent to have been given by the individual.

4. USE AND DISCLOSURE OF PERSONAL INFORMATION

SomaLife shall only use or disclose personal information for purposes which are reasonably appropriate in the circumstances and which fulfill the purposes for which the personal information was collected or which are otherwise permitted by legislation.

5. ACCESS TO PERSONAL INFORMATION

When required by legislation, SomaLife shall provide to an individual, upon request of the individual, that individual’s personal information which is under the control of SomaLife, details about the ways in which the individual’s personal information is being used by SomaLife and details about the individuals and organizations to whom the individual’s personal information has been disclosed.

When required by legislation, SomaLife shall correct an error or omission in the individual’s personal information and send the corrected personal information to each individual or organization to whom the individual’s personal information was disclosed in the previous one year period.

6. CARE OF PERSONAL INFORMATION

SomaLife shall make a reasonable effort to ensure that personal information collected by or on behalf of SomaLife is accurate and complete. SomaLife shall protect personal information in its custody or under its control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

7. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

As required by legislation, SomaLife shall retain personal information for such reasonable period of time that the individual has a reasonable opportunity to obtain access to it. As required by legislation, SomaLife shall destroy documents containing personal information or remove the means by which the personal information may be associated with a particular individual when the purpose for which the personal information was collected is no longer served by its retention and the retention is no longer required for legal or business purposes.

8. REQUESTS TO THE PERSONAL INFORMATION ADMINISTRATOR

An individual shall submit a request in writing to the Personal Information Administrator if the individual wishes to:

• have access to that individual’s personal information which is under the control of SomaLife;
  
• have access to details about the ways in which that individual’s personal information is being used by SomaLife;
  
• have access to details about the individuals and organizations to whom the individual’s personal information has been disclosed by SomaLife;
  
• have access to details about SomaLife’s policies and practices relating to personal information;
  
• have access to details relating to the complaint process set out herein; or
  
• correct an error or omission in that individual’s personal information.

SomaLife’s process to respond to complaints that may arise is as follows:

a. Submission of Complaints
An individual wishing to submit a complaint relating to SomaLife’s collection, storage, use or disclosure of that individual’s personal information may submit a complaint in writing to the Personal Information Administrator within 30 days of learning of the action complained of.

b. Review of Complaints
The Personal Information Administrator shall review complaints, give them and the underlying circumstances reasonable consideration and provide the individual with a meaningful response within 30 days of receiving the complaint unless, due to the complexity of the complaint or other matters beyond the control of the Personal Information Administrator, reasonable further time is required.

c. Reconsideration of Complaints
If the individual’s complaint is not resolved at the initial step set out above, the Personal Information Administrator shall, upon the individual’s written request, submit the written complaint to a senior officer, manager, or other responsible person who shall review the complaint and the Personal Information Administrator’s response to the complaint and within 30 days shall provide the individual with a further, meaningful response.

d. Cooperation of Individual Submitting Complaint
Where required by SomaLife for the purpose of satisfying SomaLife’s obligations under this process, the individual shall provide his or her co-operation and assistance to SomaLife in its efforts to understand and assess the merits of that individual’s complaint.

d. Dismissal of Complaints
SomaLife may dismiss a complaint for reasons including (but not limited to) the individual’s failure to raise or pursue the complaint in a timely manner, the individual’s failure to abide by his or her obligations under this process, the absence of merit or reasonableness (including frivolousness or vexatiousness) in the complaint or the fact that the complaint or the proposed resolution is contrary to SomaLife’s obligations under applicable legislation.

e. Confidentiality of Complaints
Except where disclosure is necessary for the purposes of investigating a complaint, implementing a resolution or as required by law, SomaLife shall make reasonable efforts to respect the sensitivity of the situation and to hold in confidence the individual’s identity and/or the nature of the complaint.

f. Other Proceedings
This process does not bar or prohibit individuals from accessing their rights in another forum, including under the processes provided in any applicable legislation. Where a complaint is raised in another forum, however, SomaLife may halt (or refuse to initiate) any proceedings initiated or pending under this process.

For the purposes set out herein and in the Act, the contact information for SomaLife’s Personal Information Administrator is: