Privacy Policy

This privacy policy (the “Privacy Policy”) describes how your Personal Information, including any data you may provide, is collected and processed, by Lumiera Health Inc., its subsidiaries, divisions and affiliates (“Lumiera”, “we”, “us” or “our”) when you visit or make a purchase from www.lumiera.ca, www.holizen-lumiera.myshopify.com, www.holizen.com or www.mondias.ca (the “Sites”) and in general during our relationship with you.

Please read this Privacy Policy carefully.  By using our Sites or otherwise providing us with your Personal Information, you are hereby consenting to Lumiera’s collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy. If you do not consent to the practices described in this Privacy Policy, you may not continue to use the Sites.

  1. YOUR PRIVACY

The protection of your Personal Information is important to us, we are committed to protecting and ensuring the confidentiality of the Personal Information we receive from you, in accordance with the applicable laws. We will only use your Personal Information, whether submitted to us using the Sites or otherwise, to serve you as a customer and for the purposes described in this Privacy Policy. Your Personal Information will be treated with diligence and will only be used or disclosed in accordance with your consent, this Privacy Policy, or the applicable laws.

  1. PERSONAL INFORMATION WE COLLECT

Lumiera only collects Personal Information that is strictly necessary for the Purposes described in section 3 (How do we Use of Your Personal Information), and particularly when you (i) visit our Sites, (ii.

 When you visit the Sites, we automatically collect certain information about your device, including but not limited to information about your web browser, system information, type of device, IP address, your Internet service provider, your time zone, the date and time of your visit, and some of the cookies that are installed on your device. Additionally, as you browse the Sites, we collect information about the webpages or products that you view, what websites or search terms referred you to the Sites, and information about how you interact with the Sites. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

  • “Cookies” are data files that are stored by a website on your device or computer or in your Internet browser’s temporary memory and often include an anonymous unique identifier. We may use cookies to save your preferences for our Sites or to collect statistics related to our Sites. You will be asked for your consent and you may change your cookie settings or delete them in your Internet. You may also set your browser to not accept "cookies", but this may restrict, limit, prevent or prohibit access to and/or use of all or part of the Sites. We do not use geo-location data in a manner that would identify you personally. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. For your convenience, here are links to the cookie management pages of some Internet browsers to help you manage or delete cookies:
  • Internet Explorer
  • Chrome
  • Safari
  • Firefox

These cookie management pages and their addresses may be modified from time to time.  Lumiera is not responsible for updating the above links or the content of these pages. 

  • “Log files” track actions occurring on the Sites, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. 
  • “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Sites.

Additionally when you create an account on the Sites, make a purchase or attempt to make a purchase through the Sites, or when you contact us through the Sites, or signup to our newsletter or exclusive offers, we collect certain information from you, including but not limited to: your name, billing address, shipping address, payment method including credit card information (including your billing and payment history with us), email address, phone number, business contact information (company name, physical and email addresses, and telephone number). We refer to this information as “User Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and User Information.

We will require your consent at the time of collection of your Personal Information and you will be notified directly of the Purposes and we will again require your consent for any changes to the Purposes following a procedure to obtain your express confirmation that you have read and understand the Privacy Policy and that you consent to the collection, use and disclosure of your Personal Information for the Purposes in accordance with the provisions of this Privacy Policy, as amended from time to time. If you have any questions regarding your consent or the Purposes, you may contact our Privacy Officer at any time at .

The Sites are not intended for individuals under 16 years old. We do not knowingly collect information from children to sell or promote our products or services. Visitors must have an age of at least 16 years to submit registration. If you believe a person below the age of 16 has submitted Personal Information to Lumiera, please contact our Privacy Officer at info@holizen.com immediately and we will use reasonable efforts to promptly remove that information from our systems.

  1. HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the User Information that we collect to: 

  • fulfill any orders placed through the Sites (including processing your payment information, arranging for shipping, and accounting purposes (for invoices and/or order confirmations));
  • communicate with you, for customer support, responding to your inquiries and information request, notifying you of any recalls or safety issues; 
  • screen our orders for potential risk or fraud related to our transactions with you, or any security or technical issues; 
  • when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services;
  • protect against harm to the rights, property, or safety of Lumiera, its customers, its employees, or the public, as required or permitted by law; and
  • comply with legal or regulatory requirements.

We use the Device Information that we collect to: 

  • help us screen for potential risk and fraud (in particular, your IP address);
  • monitor, improve and optimize our Sites and communications with you (for example, by generating analytics about how our customers browse and interact with the Sites, and to assess the success of our marketing and advertising campaigns); and
  • provide you with targeted advertisements or marketing communications we believe may be of interest to you;
  • develop new services and features to meet your needs as a customer as well as in aggregate form, as a statistical measure, but not in a manner that would identify you personally. 

Unless you subscribe to our newsletter or exclusive offers on the Sites, we will not use any Personal Information provided by you through the “Contact Us” form, link or box of our Sites or via telephone for unsolicited marketing purposes. 

We may anonymize your Personal Information in a way that it can no longer reasonably be associated with you. We may use anonymized information or share it with third parties for any legitimate business purpose, including to: help us understand trends and customer needs; assist in product selection, ordering, and sizing; introduce new product and optimize our Sites’ rankings in third party search engines. 

For the purpose of this Privacy Policy, the use of Lumiera of your Personal Information as described in this section 3 defined as the “Purposes” of the collection, use and disclosure of your Personal Information. 

  1. DISCLOSURE OF YOUR PERSONAL INFORMATION 

We will not disclose any of your Personal Information to third parties, except as described in this Privacy Policy and for the purposes set forth in this Privacy Policy with your consent or as required or permitted by the applicable laws. 

We will ensure that the use of your Personal Information is consistent with the Purposes and that reasonable measures have been or will be implemented to protect your Personal Information against any unauthorized access, use or disclosure. 

We may share, without your consent, your Personal Information with service providers that we use to facilitate or outsource one or more aspects of the operation of our Sites or our business Personal Information, provided that any use of the information is in accordance with the Purposes, and such information is necessary for the performance of their functions. For example, we use Shopify to power our online store (you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy). We also use Google Analytics to help us understand how our customers use the Sites (you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/ and you can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout). These service providers are subject to confidentiality and security agreements with Lumiera and other legal restrictions that prohibit their use or unauthorized access of any Personal Information we provide to them for any purpose other than to facilitate specific processing operations in accordance with the Purposes. Any disclosure of your Personal Information for purposes other than the Purposes will require your prior consent. 

Lumiera’s head office is located in Quebec, Canada. In some cases, Personal Information that we manage may be processed and stored outside Quebec or Canada, such as the United States, and therefore may be available to the courts, law enforcement, or other government authorities under lawful orders and laws applicable there. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with our Privacy Policy and the applicable privacy laws. To the extent we are required by law, such disclosure will be the subject of a written agreement that takes into account, among other things, the results of our risk assessment and, where applicable, the terms and conditions agreed upon to mitigate any identified risks. 

Finally, we may also share your Personal Information, when we, in good faith, believe disclosure is appropriate, to comply with the applicable laws and regulations, to respond to a court order, subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our own rights or property or the rights, property or safety of our users or others.

  1. BEHAVIOURAL ADVERTISING 

As described in section 3 above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (NAI) educational page at www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

 You can opt out of targeted advertising by using the email below: 

  • info@holizen.com 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/

These targeted advertising management pages and their addresses may be modified from time to time. Lumiera is not responsible for updating the above links or the content of these pages.

  1. DO NOT TRACK 

Please note that we do not alter our Sites’ data collection and use practices when we see a Do Not Track signal from your browser.

  1. ANTI-SPAM 

We are committed to providing transparency with respect to our practices in complying with Canada’s anti-spam law (CASL). From time to time, we may send commercial electronic messages (“CEM”), including (i) to our current or potential clients (whether individuals or businesses) (e.g., for prospecting purposes or to respond to an inquiry or request for information); and (ii) to our current or potential service providers or business partners. We may also delegate the distribution of Lumiera’s CEM to a third party service provider, in which case the CEM will be identified as being sent on behalf of Lumiera. 

We only send CEMs to those recipients that have either provided their express consent to receive CEM from Lumiera, or where permitted by law, including without limitation (i) due to an existing business relationship between Lumiera and you; (ii) within a certain period after the end of any such business relationship; (iii) within a certain period after an inquiry or request for information by you; (iv) in the form of a single CEM, following a referral by a current Lumiera client, service provider, business partner, or employee who also has a personal, family, or business relationship with you; (v) in the event that you conspicuously published your email address or voluntarily disclosed it to Lumiera or one of our employees or agents (without an indication that you do not wish to receive unsolicited CEM).

If you wish to stop receiving CEM from us, you may do so by using the unsubscribe mechanism found at the bottom of any CEM, or by contacting us at info@holizen.com with “UNSUBSCRIBE” in the subject header. We will remove your electronic address from our mailing list within 10 business days.

  1. CONFIDENTIALITY & SECURITY MEASURES 

To protect the confidentiality of your Personal Information and ensure the security and fulfillment of your orders through our Sites, Lumiera maintains security measures in accordance with the industry standards. We are committed to using appropriate security safeguards to protect your Personal Information during collection, use, disclosure, retention and destruction via physical, administrative, contractual, and technological safeguards to protect your Personal Information under our control from loss, unauthorized access, misuse, or alteration. 

Access to Personal Information is restricted to authorized personnel who require such information to properly perform their duties, and access is limited to information that is strictly necessary for the performance of those duties. Further, we insist that our service providers implement similar safeguards to protect the Personal Information of Lumiera’s customers. 

Nevertheless, due to the nature of the Internet and the technologies that result from it, no systems are impenetrable, the security measures undertaken by Lumiera may not fully protect your information in all cases and Lumiera cannot guarantee that there will not be a breach in the confidentiality of your Personal Information. You should thus exercise care in using our Sites and act with caution when transmitting Personal Information to us by e-mail, since it is generally not a secure method of transmission. If you believe that your Personal Information held by Lumiera has been compromised, we urge you to notify us promptly. You are responsible for maintaining the confidentiality of your passwords. We have the right to assume that anyone accessing one of our Sites using your account password has the right to do so. You will be solely responsible for the activities of anyone accessing our Sites using your account password. You must promptly change your password if you see a risk of it being compromised. 

In the event that a breach of confidentiality involving your Personal Information occurs or is suspected, such as an unauthorized access, use or disclosure, the loss of Personal Information or any other breach of protection, Lumiera undertakes to take reasonable measures to reduce the risk of harm being caused and to prevent new incidents of the same nature from occurring. Lumiera will notify you, in accordance with the applicable laws, of any such breach of confidentiality where your Personal Information is concerned.

  1. DATA RETENTION AND DESTRUCTION 

Your Personal Information is held in the Shopify cloud computing system. As mentioned in section 4 above (Disclosure of Your Personal Information), in some cases, Personal Information that we manage may be disclosed, processed, or stored in other Canadian provinces or territories, or abroad and therefore made available to their government authorities and subject to the laws of those provinces, territories or countries. We take all reasonable steps to ensure that your Personal Information is treated securely in accordance with the applicable laws and this Privacy Policy. 

Your Personal Information will only be retained for the limited duration required to fulfill the Purposes described herein or as otherwise authorized by you, or as is otherwise necessary to protect our interests or comply with the applicable laws. Once the Purposes have been fulfilled and there is no longer any legitimate need to use your Personal Information or until you withdraw your consent, we will delete, destroy, aggregate, or otherwise anonymize your Personal Information, subject to any retention period provided by the applicable laws.

  1. YOUR RIGHTS

You have the right to access Personal Information we hold about you, notably to ensure that it is accurate, complete, and up-to-date, and to ask that it be corrected, updated, or deleted. If you would like to exercise this right, please address such request to our Privacy Officer at info@holizen.com or at the contact information indicated in section 14 below. We undertake to respond to your request with diligence and no later than 30 days from the date of receipt of your written request. 

You may at any time ask Lumiera to stop sending you ECM and other information by contacting us at info@holizen.com. In addition, we routinely provide opt-out or withdrawal instructions in our ECM to allow you to remove your name from future mailings. 

You may also withdraw your consent to the collection, use, and disclosure of your Personal Information at any time by contacting our Privacy Officer at info@holizen.com. Upon receiving your request, we will undertake to delete any of your Personal Information held by Lumiera within a reasonable time, subject to any Personal Information that may need to be retained for purposes required or permitted by the applicable laws.

  1. OTHER WEBSITES 

The Sites may contain links to other websites or Internet resources operated by third parties over which Lumiera has no control, including those belonging to our partners, such as Google Pay or Shop Pay. When you click on one of these links, you are contacting another website or Internet resource that may collect information about you that you voluntarily provide or that is obtained through the use of "cookies" or other such technologies.

Please review the third-party website’s privacy policy or similar document to determine whether cookies or other tracking technologies are used by the third-party website. The privacy practices of third-party websites are outside the control of Lumiera. We do not assume any responsibility for such websites and other Internet resources or their collection, use or disclosure of your Personal Information.

  1. MODIFICATIONS TO THE PRIVACY POLICY

We reserve the right to update this Privacy Policy from time to time, at our discretion, without prior notice to you or any other person and without any liability to you or any other person, in order to reflect, for example, changes to our policies and practices or for other operational, legal or regulatory reasons. 

Nevertheless, should there be any material changes to our privacy practices, we will post the revised Privacy Policy on our Sites and indicate the date it was last updated. We encourage you to periodically review this Privacy Policy before using our Sites to ensure that you understand how your Personal Information may be collected, used, and disclosed and that you are familiar with the most current version. 

Any access or use of the Sites after a revised Privacy Policy has been posted will be deemed an acceptance of the revised Privacy Policy. Regardless of any changes we make to our Privacy Policy, we will only use your Personal Information in accordance with the version of the Privacy Policy in place at the time you provided your information, unless you later provide your express consent for us to do otherwise, or as otherwise permitted by law.

  1. CONTACT US

For more information about our privacy practices, if you have questions concerns, or if you would like to make a complaint regarding our Privacy Policy or the processing of your Personal Information, please contact our Privacy Officer by e‑mail at info@holizen.com or by mail using the details provided below:

 Lumiera Health Inc., 4500 Kimber, suite 26. Saint-Hubert, Quebec J3Y 8K5

Our Privacy Officer undertakes to respond to your request with diligence and no later than 30 days from the date of receipt of your written request.

This Privacy Policy is made, governed by and construed in accordance with the laws of the province of Québec and the Canadian federal laws applicable therein.

Please note that both the English and French versions of this Privacy Policy have equal legal value. In the event of any inconsistency between the English and French versions of this Privacy Policy, the French version shall prevail.

 This Privacy Policy was last updated on February 1st, 2021.