PRIVACY POLICY

The Universal Well-Being Institute Inc.  (“Universal Well-Being Institute”) believes strongly in protecting the privacy of Internet users who visit our website, located at www.universalwellbeinginstitute.com and other online platforms (the "Site”). We value the trust of those we deal with, and of the public, and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that you choose to share with us. During the course of our various programs, events, and activities, the Universal Well-Being Institute frequently gathers and uses personal information. Anyone from whom we collect such information should expect that it will be carefully protected and that any use of, or other dealing with, this information is subject to consent. The Universal Well-Being Institute’s privacy practices are designed to achieve this aim.The purpose of this Privacy Policy is to inform you about the types of personal information the Universal Well-Being Institute Inc. (as follows, “Universal Well-Being Institute”, “we” or “us”) collects, uses and discloses. This Privacy Policy applies to information that we collect and use, the choices you have regarding such use and disclosure and how you may correct that information about you when you access or use the Universal Well-Being Institute website, mobile application, or other online or mobile service that links to or otherwise presents this Privacy Policy to you. We refer to these products and services collectively as the “Services.” Generally, personal information is information that can be used to identify you or your activities on this Site or through Services offered on this Site.We are proud to demonstrate our commitment to your privacy by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.We will treat personal information in a manner consistent with the version of the Privacy Policy under which it was collected and our Privacy Policy unless we have your consent to treat it differently. Please read this Privacy Policy carefully to understand how we handle your information before providing us with any personal information and before using any of the Site. By providing us with any personal information or using any of the Site, you are signifying that you agree with all the terms of this Privacy Policy, please do not use this Services if you disagree with any part of this Privacy Policy. 1.           Information We CollectWe obtain information about you through the means discussed below when we provide the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.We collect a variety of information that you may provide directly to us. For example, we collect information from you through:           The Services you use or processing your orders.          Requests or questions you submit to us via online forms, email, webinars or otherwise.          Your participation in contests or surveys.          Any reviews that you submit about the Services.          Account registration and administration of your account.          Uploads or posts to the Services.          Requests for customer support and technical assistance. 

2.             Collection of Personal Information

This Privacy Policy applies to the collection, use and disclosure of personal information by Universal Well-Being Institute Inc.

Personal information is any factual or subjective information about an identifiable individual.  It is any information that can be used to distinguish, identify or contact a specific individual. While parts of the Services may not require you to provide any information that can directly identify you by name (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide.

Personal Information, however, does not include:

          Business contact information that is solely used to communicate with you in relation to your employment, business, or profession, such as your name, position name or title, work address, work telephone number, or work electronic address.          Certain publicly available information, such as names, addresses and telephone numbers, as published in telephone directories.          Information in the public domain is not subject to privacy legislation and as such is not included in this policy.          Where Universal Well-Being Institute customers and clients use their home contact information as business contact information, Universal Well-Being Institute considers that the contact information provided is business contact information and is not therefore subject to protection as personal information.The types of Personal Information we collect directly from you include:            Name, if you choose to provide it.          Email address          Mailing address          Phone numbers          Log-in credentials - if you create a Universal Well-Being Institute account.          Billing information and information found on a retail receipt, such as the shipping address of a gift card recipient, credit or debit card number, verification number, and expiration date.          Information about products purchases, total amount purchased or other transactions with us.          Information about your customer service interactions with us.          Demographic information such as your gender or other information you choose to provide as part of your Universal Well-Being Institute profile.          Demographic data may be used to tailor your experience on the Site and the communications you receive from us, to determine aggregate consumer preferences and purchasing patterns, and promotion evaluation, development, and implementation.          At times, aggregate information that does not identify any particular user may be compiled and shared with our affiliates and other third parties as described herein.          User-generated content you post in public forums such as when you comment on or review a program.          We will always collect your personal information by fair and lawful means. For example, you may provide your personal information when you complete a contest form, submit a promotional product request form, participate in a promotional offer, including one that requires you to submit a receipt, or contact Consumer Affairs.          We sometimes collect personal information from you through third-party service providers.          If you request that your purchase be provided to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to fulfill the shipment.          Any other information you choose to directly provide to us in connection with your use of the Services. 3.             Information We Collect Through Automated MeansWhen you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third-party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.           Websites. When you use our website, we collect and analyze information such as your IP address, browser types, browser language, operating system, software, and hardware attributes (including device IDs) referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, the date and time you used the Services, error logs, and other similar information.          Mobile Applications and Software. When you use a Universal Well-Being Institute mobile application or software, we automatically receive certain information about the mobile phone, tablet, or computer used to access the application or software, including device identifiers, IP address, operating system, version, Internet service provider, browser type, domain name and other similar information, whether and when you update the app, date and time of use, and how you use the app.          Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device.           4.   Information We Collect from Social Media & Other Content PlatformsIf you access the Services through a third-party connection or log-in (e.g., through a social network like Facebook, YouTube, Instagram, LinkedIn, or Twitter), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, your “likes” and check-ins, and your list of friends, depending on your settings on such services.If you do not wish to have this information shared, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and Terms of Service, which may permit you to modify your privacy settings. You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you enrolled in a class on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity. 5.             Information We Collect from OthersWe may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising. 6.           Children’s PrivacyThe Services are intended for general audiences and not for children under the age of 13. We generally do not knowingly collect, use, or disclose information that is identifiable to children. When we do, it is on a limited basis and with the expectation of their parents’ or legal guardian’s supervision or permission. In such cases, we strictly limit the use of that personal information to the purposes for which it was collected. We recommend that parents and guardians take steps to limit and monitor their children’s Internet activities directly, or through software and other tools. 7.           Cookies and Similar Technologies We Use to Collect InformationWe collect anonymous information about any user of the Site, without storing Personally Identifiable Information. This anonymous information may include a user’s browser type, type of computer operating system, and the domain name of the website from which the user linked to the Site. This information is collected for Universal Well-Being Institute’s internal use, such as to enhance website security, to detect broad demographic trends, to assist Universal Well-Being Institute in providing content tailored to a user’s interests and to otherwise enhance the user experience on the Site. We may use a “cookie” or similar technology to assist us to customize the Site. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Generally, these data files include information that allows a website to remember information that will make that user’s use of the website more efficient and helpful to him or her. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Cookies do not damage computer systems or files, and only the website that transferred a particular cookie to you can read, modify, or delete such cookie. As we adopt additional technologies, we may also gather information through other methods. If you don’t want to use cookies and wish to opt out of cookies with our Site, there are simple procedures in most browsers that allow you to delete existing cookies, to automatically decline cookies or to be given the choice of declining or accepting the transfer of cookies to your computer. Please review your browser instructions or help documentation to learn more about these functions to decline or selectively decline cookies. You should note that declining cookies may significantly impair your use of our Site and adversely impact site performance. 8.            How We Use Your Personal Information Whenever we collect your personal information, we will identify the purposes for which we will use that information and we will obtain your consent to such use. We, or our service providers, may use your information for various purposes depending on the types of information we have collected from and about you, in order to:            Sending you information and communications.          Complete a purchase or provide the Services you have requested, including invoicing and accounting.          Respond to your product inquiries and other request for information, to provide you with more effective and efficient customer service and optimize your experience on our Site.          Provide you with updates and information about programs and services in which you have enrolled.          Contact you by email, postal mail, or phone regarding Universal Well-Being Institute and third-party products, services, surveys, research studies, promotion efforts, special events and other subjects that we think may be of interest to you.          Customize the advertising and content you see on the Services.          Help us internally to better understand, analyze, and manage your interests and needs, and improve products, programs, and Services, including through research and reports, and test and create new products, features, and services.          Secure our websites and applications and resolve app crashes and other issues being reported.          Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.          Establish, exercise, or defend our legal rights, safety, or property, including by detecting and preventing fraud, where it is necessary for our legitimate interests or the legitimate interests of others.          We may also use your personal information as otherwise permitted by law.

9.             When and How We Obtain Your Consent

An individual’s consent is required regarding the collection and proposed use of personal information when information is collected. We obtain your consent prior to collecting, using or disclosing your personal information for any purpose. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. The form of consent that we seek will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances. In limited circumstances, we may rely on a third party to obtain your consent to the sharing of your personal information with us.Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. An individual’s consent is required before confidential information is released to outside parties. From time to time, we may collect, use, or disclose your personal information based on your consent and as permitted by law.

10.       Where We Store Your Personal InformationWe store your personal information in our offices in Canada. While your personal information is in Canada, it is subject to Canadian laws and may be subject to disclosure to the governments, courts or law enforcement, or regulatory agencies in Canada, pursuant to applicable laws.Our service providers may, from time to time, also hold your personal information in connection with the purposes for which you provided your consent. We may keep a record of your personal information, correspondence, or comments in a file specific to you.

11.          Retention of Your Personal Information

We will use, disclose or retain your personal information only as long as necessary for the fulfillment of those purposes. Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. We have established minimum and maximum retention periods and secure procedures for maintaining and destroying your personal information. We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws. 12.      User Generated Content From time to time, we may receive content from consumers as part of promotions and other functions of our Site (“User Generated Content” or “UGC”). Any UGC you submit may be publicly displayed, including on our Site, and is subject to any terms and conditions communicated to you as part of the submission process. Please remember that any information you disclose in connection with a UGC submission may become public information and you should exercise caution when deciding to disclose your personal, financial, or other information in a submission. Universal Well-Being Institute cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety. Furthermore, the Universal Well-Being Institute is not responsible for the results of such postings. 13.      Universal Well-Being Institute CommunicationsThrough our Site and various offline means, you may sign up or opt-in to receive communications from Universal Well-Being Institute. If you do not opt-in, Universal Well-Being Institute will not send you any communications, including promotional offers. Each communication sent to you by Universal Well-Being Institute contains an “unsubscribe” link or other unsubscribe mechanism, allowing you to opt out at any time. If you opt-in to receive communications from multiple brands within the Universal Well-Being Institute family of companies, and subsequently wish to opt-out, you may need to opt-out individually from each of the brands you elected to receive communications from. 14.      How We Share and Disclose Your Information

Generally, we do not disclose your personal information, and where we do, we will identify to whom and for what purposes the disclosure will be made and will obtain your consent to such disclosure. In any case, we only disclose your personal information as permitted or required by law.

Universal Well-Being Institute will share your information in the following ways:           Affiliates and Subsidiaries. We may share information we collect within the Universal Well-Being Institute Inc. company to deliver products, programs, and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.          Service Providers. We may provide access to or share your information with select third parties who perform services on our behalf. These service providers may help us operate our business and our Site and administer activities on our behalf, such as sending emails, fulfilling orders, promotions, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services. We may share your information with these third parties for those limited purposes. For instance, merchandise fulfillment and management agencies to conduct promotional activities on our behalf. Each of our service providers is required by contract or other binding means to comply with our privacy standards to protect the privacy of your personal information, and to only handle your personal information for Universal Well-Being Institute purposes. They are prohibited from using the information for its own or other purposes.          Public Forums. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Therefore, please take care when using these features.           Ad Networks and Anonymous Information. From time to time, we may share Anonymous Information about the use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted. We may have relationships with third-party service providers known as Ad Networks to serve ads on our behalf across the Internet. Using cookies and similar technologies (such as “pixel tags”, “web beacons”, and “clear GIFs”), Ad Networks collect anonymous information about your visits to our Site and other websites in order to deliver advertisements that may be of particular interest to you. This process does not involve the collection of any personal information. For example, the Ad Networks do not know your name, phone number, address or email address and we do not share any personal information about you with these Ad Networks.In connection with these Ad Networks, we adhere to the “Canadian Self-Regulatory Principles for Online Behavioral Advertising”. These Principles were developed by the Digital Advertising Alliance of Canada, a consortium of leading Canadian advertising and marketing associations, with the aim of applying consumer-friendly standards to online behavioral advertising across the World Wide Web. To opt out of interest-based advertising from third parties collecting data on the Universal Well-Being Institute website. To find out more about how Ad Networks manage the privacy of information in conjunction with delivering advertisements online, and how to opt out of information collection by these Ad Networks, you can view websites such as: http://www.youradchoices.ca and http://www.networkadvertising.org . We do not operate or control these websites, and we are not responsible for the opt-out choices available there.

15.      Online Analytics and Advertising           Analytics. We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.           Online Advertising. The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, the information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. Third parties may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. These third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick, and others) may also serve tailored ads to you as you use the Internet and Internet-connected applications and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services to assist in this activity. 16.      Openness, Access and Security Universal Well-Being Institute has a variety of convenient methods available that allow you to review, correct, update or otherwise modify information previously collected from you, including communication preferences. You may (i) modify your information on your account profile page on the applicable Site, (ii) use the Contact Us form on the applicable Site, or write us at Universal Well-Being Institute Inc., P.O. Box 39139 RPO Topsail Road, St. John’s, NL, Canada A1E 5Y7. We will make available to you any specific personal information of yours that we have collected, used or disclosed, upon your request, to the extent permitted by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes. 17.       Accuracy of Personal Information CollectedWe will ensure that your personal information is kept as accurate, complete, and up to date as possible. We will not routinely update your personal information unless such a process is necessary. We expect you, from time to time, to supply us with updates to your personal information, when required.Where the personal information we have for you is inaccurate, you can contact us to review, correct, update, or otherwise modify the personal information we have for you. In each such case, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personal information removed from our database. If you successfully demonstrate that the personal information, we have for you is inaccurate or incomplete, we will amend our records of your personal information as required.

Note that despite any request for a change to or removal of your personal information, we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. We may make commercially reasonable efforts to transmit any amended information to third parties having access to your personal information, where necessary in the circumstances.

 18.   Response Time and Fees Associated for Requesting Information on Your Personal Information Please note that requests for changes to your personal information, even those submitted through our Site, may not be effective immediately. We will attempt to respond to any requests regarding personal information as soon as reasonably possible, and in any event not later than 30 days after receipt of each such request. We will advise you in writing if we cannot respond to any of your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit. There will not be a cost to you for requesting information on your personal information or on our Privacy Policy without first providing you with an estimate of the approximate costs, if any. You may withdraw your request for access to information by notifying us within the 30-day notice period disclosed on the estimate. If you do not notify us within such 30-day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within 30 days. If after the expiry of this 30-day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.

We may request that you provide us with sufficient identification before granting you access to information regarding the existence, use or disclosure of your personal information. Any such identification information shall be used only for this purpose.

19.          How We Protect Your Personal Information 

Universal Well-Being Institute has implemented physical, organizational, contractual and technological security measures to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification.          The only personnel who are granted access to your personal information are those with a business “need-to-know” or whose duties reasonably require access to such information.          No Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to Universal Well-Being Institute via the Internet.          The security of all personal information collected through our Site is of utmost importance to us. We have taken reasonable technical, contractual, administrative, and physical security steps to protect the personal information collected from you through the Site, consistent with standard industry practice and the sensitivity of the personal information collected.          For example, if and when you provide credit card information, we use secure socket layer (SSL) encryption to protect it. These security measures are periodically reviewed.         There are some things that users of our Site can do to help protect the security of their personal information as well. For instance, no user should ever give out their username and password.         Every user should sign out of their Internet account and close their browser window each time they finish using the Internet so that other people using the same computer will not have access to their information.

20.          Third-Party Links and Features

Our Site may contain links to other websites that are not operated by the Universal Well-Being Institute. The Services contain links to third-party websites such as social media Site, and also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button). If you choose to use these Site or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function.          We are not responsible for the privacy practices or the content of those websites or services, including websites operated by affiliated entities.          The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party website or services, and not our Privacy Policy. We urge you to read the privacy and security policies of these third parties.          We provide such links only as a convenience and the inclusion of a link on any of our Site does not imply endorsement of the linked to website by The Universal Well-Being Institute.          If you provide any personal information through any such third-party website, your transaction will occur on such third-party website, and not on our Site, the personal information you provide will be collected by and controlled by the Privacy Policy of that third party. The Universal Well-Being Institute recommends that you review the privacy policies of third-party websites arrived at from links on our Site before using those websites.          If you need further assistance, please contact the Universal Well-Being Institute by writing to us at Universal Well-Being Institute Inc., P.O. Box 39139 RPO Topsail Road, St. John’s, NL, Canada A1E 5Y7 or by contacting us via the Contact Us page at www.universalwellbeinginstitute.com  21.      Changes to Our Privacy Policy

The Privacy Policy is subject to change at any time. The Universal Well-Being Institute reserves the right to amend and make changes in this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Such changes will take effect immediately upon posting. For your convenience, the last revised date of the current Privacy Policy will be posted at the top of this page. We recommend that you review this Privacy Policy regularly for changes.

By continuing to interact with us following such changes, including by using our Site, you are confirming that you have read, understood, and agree to the latest version of this Privacy Policy you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, please do not continue using our Site.

 22.        Governing LawThis Privacy Policy is governed by, and interpreted and enforced in accordance with, the laws in force in the Province of Newfoundland and the federal laws of Canada, excluding any conflict of laws, rule or principle which might refer such interpretation to the laws of another jurisdiction. This Privacy Policy is provided in accordance with and subject to Canadian law.  If you access this Site from a location outside of Canada, you agree that your use of this Site is subject to the terms of this Privacy Policy and the Terms of Service. 23.      Contact InformationPlease feel free to contact us if you have any questions, concerns, or complaints about the Universal Well-Being Institute's Privacy Policy or the information practices of the Services. You may contact us as follows: P.O. Box 39139RPO Topsail RoadSt. John’s, NLCanada A1E 5Y7 [email protected]