Privacy policy

At Cizzle Brands Ltd. (“Cizzle”), our mission is to elevate the game in health and wellness. Part of what wellness means to us is making sure that all our stakeholders feel confident and secure in their dealings with us, and that includes making sure that your personal information is dealt with thoughtfully, accurately and securely. This Privacy Policy describes how we collect, use and disclosure your personal information on our websites and beyond, including www.cizzlebrands.com, www.cwenchhydration.com and www.spokennutrition.com.

WHAT IS PERSONAL INFORMATION?

From a legal perspective, the definition of “personal information” has different meanings depending on the legislation being referenced. But for the purposes of this Privacy Policy, "personal information" is any information about an identifiable individual, other than an individual's business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities. 

WHAT PERSONAL INFORMATION DO WE COLLECT?

Types of Information We Collect

We collect and maintain different types of personal information, depending on the nature of the interaction we have with you. 

When you make purchases from us or otherwise submit an inquiry to us, we may collect the following: 

• contact and identification information, such as your name, address, telephone number, e-mail address, date of birth, and gender;
• personal information in connection with your request for certain products or services that you seek from us;
• social media profile information for future contact and extended customer experience;
• additional service-related information concerning the products or services that we provide to, or receive from, you;
• payment information, including your credit card information, and information necessary for the fulfillment of your orders;
• purchase history, which we sometimes aggregate with similar information from other customers to suggest products;
• content of consumer support communications and adverse event reporting; and
• statistics about your session to improve your future online experience.

Websites

When you visit any of our websites we may collect information related to your visit including the IP address and domain used to access our websites, the type and version of your browser, the website you came from to access our website(s), the page you entered and exited at, any website page within our website(s) that is viewed by that IP address and what country you are from. We use this information to monitor our websites' performance (such as number of visits, average time spent, page views) and for our business purposes such as: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our websites.

We may also use "cookie" technology to obtain non-personal information from visitors to our websites. Cookies are pieces of information stored on your computer by a website so preferences are remembered on future requests. Pixel tags (also known as web bugs, web beacons, clear/invisible/tracker GIFs) are signals sent from certain websites or e-mails used to pass certain information to our servers to personalize the websites and to track your usage. We do not save personal information on cookies or through use of pixel tags without your permission. Rather, cookies and pixel tags are used to optimize the performance and functionality of the websites, and to personalize the websites for you and present you with content and offers specific to your interests.

Most browsers accept cookies automatically but can be configured not to accept them or to indicate when a cookie is being sent. We do not extract personal information in this process, nor do we provide this information to third parties. Cookies allow us to customize your user interface to speed up the navigation process and to make the website experience more efficient. If your browser is configured to reject cookies, you may not be able to use the features of the websites. When you log in, a cookie can tell us whether you've visited us before or are a new visitor. We do use the cookie to help us identify website features in which you have the greatest interest, so that we can provide you with more of what you want.

Our websites may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. We cannot be responsible for how such third parties collect, use, or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

We may also use third-party service providers to monitor and analyze the use of our website or Services. Google Analytics is a web analytics service offered by Google Inc. (“Google”) that tracks, monitors and reports traffic on our websites. Google tracks information like (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Website that you visit; and (iv) other websites you may have visited before visiting our websites.

Google may also transfer this information to other third parties where they are required to do so by law, or where such third parties process the information on their behalf. You can opt-out of having your activity on the website made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about your activity. For more information on Google’s privacy practices, please visit: https://policies.google.com/technologies/partner-sites.

Finally, our websites may provide you with an opportunity to interact with others and share your thoughts, information, content and materials (collectively "User Generated Content").  You are solely responsible for the User Generated Content that you post on our websites.  Unless explicitly stated otherwise, any User Generated Content that you post onto our websites (including your username) will be made publicly available. As such, do not post any personal information onto our websites (such as your name or email address) if you wish to remain anonymous.

Information Received from Third Parties

As a general rule, we only collect personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties and may receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

HOW WE USE PERSONAL INFORMATION

We collect personal information to enable us to manage, maintain, and develop our operations, including for example:

• to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
• to send you promotional and other marketing materials that we think may be of interest to you;
• to enable you to register and access an account with us;
• to obtain and process payments for the products and services that we provide to you;
• to tailor your online experience based on your generalized profile of usage on the website;
• to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;
• to monitor and investigate incidents and manage claims;
• to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
• to protect Cizzle against error, fraud, theft and damage to our goods and property;
• to enable us to comply with applicable law or regulatory process; and
• any other reasonable purpose to which you consent.

We may use your personal information:

• as permitted or required by applicable law or regulatory requirements;
• for the purposes described in this Privacy Policy; and
• for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

DISCLOSURE OF PERSONAL INFORMATION

We generally do not share your personal information with third parties unless you consent or as otherwise permitted by law. All such sharing is done in a manner consistent with this Privacy Policy. We may also share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, we may share your personal information from time to time with our third-party information technology, data processing, payment processing, advertising/marketing, call center and age/identity verification service providers so that we may operate our business, some of which may be located in the United States. As a result, your personal information may be collected, used, processed, stored or disclosed in the United States and may potentially be accessible to law enforcement and national security authorities of that jurisdiction. However, it is important to note that in the unlikely event United States law enforcement and/or national security authorities request your personal information, it shall only be provided in strict accordance with the law and subject to all required legal permissions.  To the extent permissible, you will be informed if disclosure of your personal information is requested by law.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Cizzle through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

• for the purposes described in this Privacy Policy;
• to third party databases for the purposes of verifying your age;
• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of the regular reporting activities of Cizzle;
• to protect the rights and property of Cizzle;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent. 

YOUR CONSENT IS IMPORTANT TO US

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you purchase a product from one of our websites, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to fulfilling that order. 

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer, using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

HOW IS YOUR PERSONAL INFORMATION PROTECTED?

We maintain certain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may potentially compromise the security of your personal information.

The security of your personal information is important to us. Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

UPDATING YOUR PERSONAL INFORMATION

We will strive to keep all personal information in our files complete, up-to-date and accurate.

You or a person authorized on your behalf has the right to request to see and obtain a copy of your personal information and to request changes or corrections to inaccurate or incomplete information. 

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.

Please note that your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

If you have any questions or concerns with respect to your personal information or our information practices, you may contact our Privacy Officer at: info@cizzlebrands.com. 

PRIVACY OFFICER

We have appointed our Privacy Officer to oversee compliance with this Privacy Policy, and help us manage and monitor our compliance with privacy legislation. The contact information for our Privacy Officer is as: privacy@cizzlebrands.com.  

PRIVACY RIGHTS OF EU DATA SUBJECTS

To the extent that the General Data Protection Regulation may apply to any of our websites, each individual residing in the European Union whose personal information is processed by the website has certain rights. These are:

1. The right to be informed: This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
2. The right of access: This is your right to see what data is held about you by a Data Controller. Cizzle is the Data Controller of the information you provide.
3. The right of rectification: The right to have your data corrected or amended if what is held is incorrect in some way.
4. The right to erasure: Under certain circumstances you can ask for your personal data to be deleted. For example, this would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
5. The right to restrict processing: This gives an individual the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
6. The right to data portability: An individual has the right to ask for any data supplied directly to the Data Controller by them, to be provided in a structured, commonly used, and machine-readable format.
7. The right to object: An individual has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
8. Rights in relation to automated decision making and profiling: individuals have the right not to be subject to a decision based solely on automated processing. 

REVISIONS TO THIS PRIVACY POLICY

Cizzle, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our websites, and we encourage you to refer back to it on a regular basis. If you continue to use our websites after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide a more prominent notice or get your consent, as required by law.

INTERPRETATION OF THIS PRIVACY POLICY

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word "including" is used, it shall mean "including without limitation".

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Cizzle any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal privacy laws and its provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and any such laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.