Steeped Tea Inc. (Sipology) Privacy Policy

1. PURPOSE AND INTENT

This is the Privacy Policy of Steeped Tea Inc. and its operating groups, subsidiaries, divisions, and affiliates (collectively, “Sipology”, “we” or “us”). This policy applies to customers and consultants who are accessing sipology.com (the “Site”). This Privacy Policy does not apply to the Personal Information of Sipology employees collected and provided in the employment context, but employees who access the Site and use its services will be treated as customers in accordance with this Privacy Policy.

This Policy does not form part of any employment contract or any other contract to provide services. We may update this policy at any time. Any questions concerning this privacy policy or how we handle personal information can be sent by email to support@sipology.com, by phone at 716-408-0875, or by mail to Steeped Tea Inc. (Sipology), 1100 Military Rd. Kenmore NY 14217-2514-003

This Policy supplements and forms a part of the Terms and Conditions.

2. INFORMATION USE

• CONSENT & PRIVACY
  Your phone number will only be used for Sipology SMS communications. It will not be sold or shared with third parties for marketing purposes.
• TYPES OF MESSAGES
  You may receive text messages related to:
  · Order updates and account notifications
  · Consultant or event reminders
  · Promotional offers and specials (where applicable)
  · Customer service or follow-up communications
• MESSAGE FREQUENCY
  Message frequency may vary. You may receive up to 4 messages per month.
• FEES & CHARGES
  Standard message and data rates may apply, depending on your mobile carrier plan. International rates may also apply if you are outside Canada or the U.S.
• OPT-IN METHODS
  You may opt in by:
  · Checking the SMS consent box on Sipology forms
  · Signing up through our website or consultant portal
  · Providing verbal consent during a customer service interaction
• OPT-OUT
  You can unsubscribe at any time by replying STOP to any Sipology SMS. You may also contact us directly to be removed from our list.
• HELP & SUPPORT
  Reply HELP to any Sipology SMS for assistance. You can also contact us at https://www.sipology.ca/pages/contact.
• STANDARD DISCLOSURES
  · Message and data rates may apply
  · Message frequency may vary
  · Reply STOP to opt out
  · Reply HELP for support

3. COOKIES AND ANALYTICS

This Site is cookie-enabled to give you a more customized user experience. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Cookies are used to collect information on the number of visitors to our Site and the number of pages viewed. It is also used to provide relevant information to our visitors and for Site and system administration, including research and development, user analysis and business decision-making.

We may also use Google Analytics to collect non-personally identifiable information regarding visitor behavior and visitor demographics on some of our Services and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and processing of data here: https://tools.google.com/dlpage/gaoptout.

4. DATA PROTECTION PRINCIPLES

We will comply with applicable data protection law, which provides that the personal information we hold must be: (i) used lawfully; (ii) collected only for valid purposes and not used in any way that is incompatible with those purposes; (iii) relevant to the purposes we have disclosed and limited only to those purposes; (iv) accurate and kept up to date; (v) kept only as long as necessary for the purposes we have disclosed; and (vi) kept securely.

5. RESIDENTS OF CALIFORNIA - WHAT PERSONAL INFORMATION IS COLLECTED AND HOW IT IS USED

California law affords California residents certain rights regarding their personal information. California Residents should review the Sipology Notice to California Residents under the California Consumer Privacy Act (available here), which supplements and forms a part of this Privacy Policy, and informs what information is collected by Sipology from customers, what we do with it, and the rights customers have under the California Consumer Privacy Act.

For Consultants and former Consultants, please refer to the INDEPENDENT CONSULTANT AGREEMENT CCPA ADDENDUM and the PRIVACY NOTICE

TO CALIFORNIA INDEPENDENT CONSULTANTS REGARDING THE COLLECTION OF PERSONAL INFORMATION (available here) for the information collected by Sipology from Consultants, what we do with it, and the obligations that Consultants have with regards to personal information protected by the CCPA. Each of these documents are available in The Cellar.

We will only use your personal information for the purposes we have disclosed in our notices described in paragraphs above.

6. DATA SECURITY

While no data security system can fully protect personal information from unauthorized data breaches, Sipology has implemented reasonable safeguards and controls, consistent with its legal obligations. Sipology is committed to: (i) seeking to safeguard all personal information to us; (ii) seeking to ensure that it remains confidential and secure; and (iii) taking all reasonable steps to ensure that personal privacy is respected. All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information of consultants to only those consultants, and third parties who need to know that information for the purposes identified in our notice(s) discussed in the paragraphs above. Sipology provides consumer’s personal information to consultants as service providers and pursuant to the consultant’s contractual obligations to comply with all necessary privacy protections. Sipology does not share consumer personal information with third parties. See the notices discussed in the paragraphs above.

We have put in place procedures to deal with any suspected data security breach and will notify those subject to the breach and any applicable regulator of a suspected breach where we are legally required to do so.

7. DATA RETENTION

We will only retain personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize personal information so that it can no longer be associated with an individual, in which case we may use such information without further notice.

Once an individual is no longer a consultant, and or customer of Sipology, we will retain and securely destroy personal information in accordance with Sipology’s record retention policies.

8. CHANGES TO THIS PRIVACY POLICY

As we strive to improve our practices, we may review Sipology’s Privacy Policy from time to time. This Privacy Policy is not a contract and we reserve the right to change this policy at any time and provide notification of those changes by posting an updated version of this policy on the Sipology website.