Last update: December 18, 2024

Origin Nature Inc. (“Origin”, “we”, “us”, “our”) respects your privacy and is committed to maintaining your trust. While most of Origine’s activities do not involve the collection of personal information, the purpose of this Privacy Policy (the “Policy”) is to describe our privacy practices regarding the collection, use, storage, communication and protection of your personal information by or on behalf of Origine when you use our website (the “Site”).

1. PERSONAL INFORMATION

For the purposes of this Policy, “personal information” means any information which relates to a natural person and that directly or indirectly allows that person to be identified.

2. BASIS FOR COLLECTING PERSONAL INFORMATION

Your consent

As required by the privacy laws applicable to us, Origine collects most of your personal information based on your free consent, favouring collection directly from you.

Other permissible legal basis, such as the performance of our contracts

As permitted by applicable privacy laws, Origine may collect personal information without your consent, for example, to comply with our obligations under applicable laws or to fulfill our contracts.

3. PERSONAL INFORMATION THAT WE COLLECT

Depending on the nature of your relationship with Origine, we may collect personal information, including information collected via an Origine form, when you access our Site, subscribe to our newsletter or contact us: for example, contact information such as your first and last name, date of birth, province of residence, e-mail address and telephone number.

4. PURPOSES FOR COLLECTING PERSONAL INFORMATION

We only collect personal information that we deem necessary for the following purposes:

• To verify your age to access the Site;
• To send you marketing communications, such as newsletters;
• To communicate with you by telephone, for example for solicitation purposes;
• To contact you following your contact request;
• To send you communications following your purchase;
• To comply with or act under any applicable law or regulation;
• For any other purpose to which you have consented.

If we wish to use your personal information for a purpose not mentioned above and for which you have not consented, we will ensure that we seek appropriate consent or inform you of the change, where required by law.

5. COMMUNICATION OF PERSONAL INFORMATION

Your personal information will not be sold to third parties. We share your personal information with third parties in order to: (i) achieve the purposes described above, (ii) respond to requirements or requests made under applicable laws, (iii) perform tasks related to our business activities, which are entrusted to us by our members. In most cases, you have already consented to such sharing. Sometimes, applicable laws also authorize us to share your personal information with third parties without your consent, in specific cases. More specifically, we may need to share your personal information, sometimes without your consent:

With our employees and officers

In the carrying out of our enterprise, our employees and officers may have access to your personal information, for example when you contact us. Their access is limited to what is necessary for the performance of their duties.

With our partners and collaborators

Our partners and collaborators sometimes need to access or receive certain personal information in order to perform their services (for example, hosting, online payment and communication services). In such cases, we endeavor to implement reasonable contractual and technical safeguards to ensure that these third parties keep all personal information they process strictly confidential. Please note that these third parties may not be located in your country, province or territory of residence. For more information on this subject, please consult the “Third parties located abroad” section.

With authorities or persons authorized by law

We may share your personal information if required to do so by law or if we believe in good faith that such action is necessary to:

• Comply with applicable laws;
• Comply with the order of a competent judicial authority in any jurisdiction;
• Comply with legal proceedings;
• Protect and defend the rights or property of Origine;
• Enforce or verify your compliance with any part of your contracts with us, if applicable;
• Prevent fraud or other illegal activity perpetrated through the service; or
• Act in urgent circumstances to protect the personal safety of users, our services or the public.

With potential buyers of our company

We may need to share your personal information without your consent in the event of a merger, acquisition or sale of all or part of our business, for example, as part of a due diligence review. In such a case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction.

Third parties located abroad

Your personal information may be disclosed and stored outside your province, state, territory or country of residence. Our partners and collaborators may be located in Canada or in other countries. In such cases, we ensure that contractual agreements are in place with these third parties to ensure that your personal information is handled in accordance with the laws applicable to us.

6. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

Origine will retain your personal information only as long as necessary to fulfill the purposes for which it was collected, in accordance with our internal document retention policies, to comply with applicable legal, tax or regulatory requirements. After the specified retention period, any relevant personal information held by Origine will be destroyed, deleted or anonymized.

7. SECURITY

In order to protect your personal information, we have implemented practices relating to the security of the personal information we hold. These internal practices govern the collection, use, disclosure, retention and destruction of personal information, as well as the handling of complaints, information security and personal information governance at Origine. They also provide the framework for the implementation of privacy impact assessments, when required, as well as the prevention of and response to potential confidentiality incidents.

In addition, your personal information is held using reasonable security measures to preserve the integrity and confidentiality of your personal information. We maintain our services and all associated information with technical, administrative and physical safeguards to protect them against loss, unauthorized access, destruction, misuse, alteration and improper disclosure. These safeguards vary according to the sensitivity of the information in our possession and are based on the best industry standards. Unfortunately, no information transmission or storage system can be guaranteed to be 100% secure.

8. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

Under applicable laws, you may have certain rights with respect to the personal information we hold about you. For example, you may have the right to:

• Obtain access to the personal information we hold about you;
• Require the rectification of inaccurate, incomplete or equivocal personal information held by us;
• Request the de-indexation of your personal information;
• Obtain additional information, for example, on the categories of third persons to whom we disclose your personal information;
• Request the communication of your personal information in a structured, commonly used technological format;
• Withdraw your consent at any time;
• Refuse promotional communications sent by Origine;
• File a complaint with a privacy control authority, such as a privacy commissioner or the Commission d’accès à l’information.

If you are dissatisfied with our handling of your personal information or our compliance with this Policy, you may file a complaint with our Privacy Officer at info@originenature.com.

You are also entitled by law to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of personal information.

You can exercise your rights listed above by sending a written request to our Privacy Officer. He will be able to help you with your request, should you need it. We may need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any. We aim to respond to requests promptly, usually within 30 days.

In the context of the processing activities covered by this Policy, Origin does not make decisions based exclusively on automated processing producing legal effects or similar significant effects.

9. COOKIES

A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. This Policy includes in the term “Cookie(s)” other tracking technologies, including but not limited to web beacons and pixels. These tracking technologies are not necessarily stored on your computer or device. Any personal information collected with Cookies by us or on our behalf is treated with the same level of confidentiality as any other personal information we hold.

• Essential cookies.
  These Cookies are necessary for the operation of the Site. They provide basic functions and may include maintaining your current browsing session and preventing security threats. We cannot disable these Cookies in our systems without affecting the operation of the Site. However, if you wish, you can block or delete them by modifying your browser settings and forcing the blocking of Cookies on the Site.
• Non-essential cookies.
  Non-essential Cookies provide certain non-essential functionalities on our Site, for functional or analytical purposes. We will ask for your consent before using these Cookies.
  • Functional cookies:
    We use these Cookies to facilitate the non-essential functions of our site, such as the integration of content such as videos or the sharing of site content on social media.
  • Analytical cookies:
    These Cookies store information such as the number of visitors to our site or the page they have visited. They help us understand and analyze the performance of our Site and identify potential improvements.
• How to manage Cookies

  You can manage and deactivate Cookies through your browser’s Cookie settings. However, if you refuse to accept Cookies, you may not be able to use the full functionality of the Site.

9. CHANGES TO THIS PRIVACY POLICY

We revise this Policy from time to time to comply with applicable laws and our operations. If we update this Policy, we will notify you by sending you a notice either on our Site or by e-mail.