Healthy Sprouts Foods Inc.

P.O. Box 30035, 478 Dundas St. W, Oakville, ON. L6H 6Y0

Privacy Policy

ISSUED BY:	Irene Swedak, RNCP, Privacy Officer
SUBJECT:	Privacy Policy for Healthy Sprouts Foods Inc.
EFFECTIVE DATE:	October 1, 2010
REVISION DATE:	n/a

1.0 — Overview

1.1 — Preamble

Privacy of personal information is an important principle of Healthy Sprouts Foods Inc. (from here on in also referred to as “the Company” or “this Company”). This Company is committed to collecting, using and disclosing personal information responsibly and only to the extent necessary and reasonable for Healthy Sprouts Foods Inc operations as a formulator, sales and marketer of frozen organic baby and toddler foods and snacks. The Company and its directors are also diligent at being open and transparent as to how they handle personal information. This document describes the Company’s privacy policies.

1.2 — Effective Date and Revisions

The Company is required to comply with the terms of this privacy policy while it is in effect. The Company reserves the right to modify the policy at any time and the revised privacy policy will apply to all personal information that the Company currently has as well as to information that the Company may generate in the future. This policy will be in effect from October 1, 2010; until such date that an amended policy is published. If the Company changes the privacy policy, Company officials will post the amendments in their office, have copies available and publish it on the Company website.

1.3 — Personal Information

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• age, name, address, telephone or other contact information, or age and number of an individual’s children, submitted to the Company in writing, by telephone or via the website or other methods of communication
• opinions, evaluations, or comments submitted to the Company in writing, by telephone or via the website or other methods of communication; and
• existence of a dispute between the individual and the Company, or customer complaints. Personal information does not include the name, title, business address or telephone number of an employee of an organization and thus is not protected by privacy legislation nor covered by this policy.

1.4 — About Healthy Sprouts Foods Inc

Healthy Sprouts Foods Inc date of inception and incorporation: March 31st, 2004.

Services: Formulation, Sales, and Marketing of frozen organic baby and toddler foods, and frozen and/or shelf-stable or refrigerated snack foods.

2.0 — Purpose

The purpose of this document is to outline the policies in effect that govern Healthy Sprouts Foods Inc's collection, storage, retention, use and disclosure of personal information. These rules are in place to protect the Company, employees of the Company, and volunteers. Failure to comply with this policy exposes Healthy Sprouts Foods Inc to a breach of confidentiality resulting in potential legal liability and loss of confidence.

3.0 — Scope

This policy applies to the ownership, staff and volunteers of Healthy Sprouts Foods Inc and to contractors and consultants that may provide services to Healthy Sprouts Foods Inc on occasion.

4.0 — Policy

4.1 — Collection of Personal Information: The collection of personal information is limited to that which is necessary for our purposes.

PRIMARY PURPOSES:

• To collect information for the purposes of maintaining a customer database
• To collect information for the purposes of using the customer database to further and improve business operations and determine demographics
• Newsletters
• Promotional Seminars, Workshops, and surveys

DISCLOSURE: Healthy Sprouts Foods Inc uses and discloses personal information only for purposes for which we have consent (implied or written), or as required or determined by law. The Company will disclose personal information (to the extent which is consented to) as described below:

• In the event of legal matters which threaten or defame the Company, its directors and/or employees, volunteers or representatives
• In the event that a customer wishes to, or is asked to, provide a testimonial ACCURACY: The Company endeavours to maintain accurate and up-to -date records.

4.2 — The Company Protects Personal Information:

The Company understands the importance of protecting personal information. For that reason, the Company has taken the following steps:

• Staff is trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this privacy policy.
• Paper copy is kept in a locked file cabinet/ and or locked office, in a supervised area.
• Passwords are used on computers to protect electronic data, in a supervised area.
• Paper information is transmitted through sealed, addressed envelopes or boxes by postal service.
• The Company web-site is protected by security safeguards appropriate to the sensitivity of the information with the proper firewalls and virus protection in place.
• Verbal personal information is collected and used in such a manner that the information is not overheard by persons other than the staff.

4.3 — The Company Retains and Destroys Personal Information Records:

The Company will retain personal information for some time to ensure that the Company can answer any questions you might have about products or services the Company provides and for the Company’s accountability to external regulatory bodies. In compliance with the requirements of other legislation, the Company will keep records for a minimum of 10 years. The Company will keep any personal information relating to general correspondence (i.e. newsletters, seminars and marketing activities) for about 12 months after the newsletter ceases publication or a seminar or marketing activity is over. You can ask the Company, in writing, to restrict its uses and disclosures of your personal information at any time. The Company will discontinue to use or to disclose your personal information after a written revocation of your implied or informed consent is received, unless the Company has already acted in reliance upon this consent, or as directed by legal requirements. The Company destroys paper files containing personal information by shredding. The Company destroys electronic information by deleting it and, when hardware is discarded, the Company ensures that information on the hard drive is destroyed.

4.4 — You Can Look At Your Information:

Upon request, you have the right to see what personal information the Company holds about you. The Company will need to confirm your identity, if the Company does not know you, before providing you with this access. The Company reserves the right to charge a nominal fee for such requests.

The Company may ask you to put your request in writing. If, for legal reasons, the Company cannot give you access, the Company will notify you within 30 days, and provide the reason, as best they can, why they cannot give you access. If you believe there is a mistake in the information the Company has about you, you have the right to ask for it to be corrected. The Company may ask you to provide documentation that Company files are incorrect. Where a mistake has been made, the Company will make the correction.

4.5 — Do You Have A Question?:

The Company Privacy Officer, Irene Swedak, RNCP, can be reached to answer any questions or concerns you might have at:
P.O. Box 30035, 478 Dundas St. W.
Oakville, ON. L6H 6Y0
416-948-9355
irene.swedak@healthysprouts.ca

If you wish to make a formal complaint about the Company’s privacy practices or the application of those practices, you may make it in writing to the Company Privacy Officer, who will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and explanation in writing.

5.0 — Enforcement

Any person found to have violated this policy may be subject to disciplinary action, up to and including termination. Use of any personal information in the possession of or under the control of Healthy Sprouts Foods Inc for illegal activity is grounds for immediate dismissal of office, and the Company will cooperate with any legitimate law enforcement activity.

6.0 — Further Information

This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 KENT STREET | OTTAWA, ONTARIO | K1A 1H3
PHONE (613) 995-8210 | TOLL-FREE 1-800-282-1376
FAX (613) 947-6850 | TTY (613) 992-9190
WEB SITE: www.privcom.gc.ca

7.0 — Revision History

This document is an original version. There are no revisions which supersede this document.