Privacy Policy

Sigan Industries Group (“Sigan”) is committed to protecting the Personal Information of our customers and our employees.
 
Each time you visit http://www.siganindustries.com  (the “Website”), place an order with us or provide us with information, you consent to the collection, use and disclosure of your information by Sigan in accordance with the terms of this Privacy Policy.
 
By visiting the Website, you acknowledge and agree that you have read and understand this Privacy Policy, and consent to the collection, use and disclosure of your Personal Information under the terms of this Privacy Policy. In most cases, we will ask you to provide explicit consent to the collection, use or disclosure of your Personal Information (as hereinafter defined), however there may be situations where consent will be implied through your actions with us.
 
This Privacy Policy describes the Personal Information we collect about you, why we collect it, how we use it, and when we share it with third parties.  As well, our Privacy Policy explains the choices you can make about how Sigan collects, uses, and discloses your Personal Information.  If our practices change, we will post an updated Privacy Policy on the Website.  For reference, the date the Privacy Policy was last updated with be noted at the bottom of the page.  You may browse our site without providing any Personal Information, however your decision not to provide us with certain Personal Information may result in Sigan being unable to properly provide you with the products or services requested.
 
Our Privacy Policy is set out below: 
 
1.0      Accountability
 
1.1 Sigan is responsible for all Personal Information under our control.
 
1.2 Employees of Sigan are responsible for the collection and processing of Personal Information on a day to day basis, each of whom are required to comply with this Privacy Policy.
 
1.3 Sigan’s Privacy Officer is responsible to ensure compliance with the Privacy Policy on behalf of Sigan and its employees.  Our Privacy Officer’s contact information can be found in Section 10 of this Privacy Policy.
 
1.4 Where we disclose or transfer Personal Information to subcontractors, suppliers, Health Canada, the United States Food and Drug Administration, related companies or third party service providers (collectively, “Third Parties”) as set out in this Privacy Policy, we use contractual and/or other safeguards to ensure that the Third Parties provide a comparable level of privacy protection.
 
1.5 Our Website may contain links to other sites, which may have privacy policies and practices that contrast with Sigan.  Our Privacy Policy does not apply to other websites that we have linked to our Website and Sigan is not responsible for the content or practices of any such website.  It is strongly recommended that you review the privacy policy of any website that you access through our Website as Sigan makes no statement as to the policies and practices of other websites. 
 
2.0      Identifying Purposes
 
2.1 Upon collection of Personal Information, Sigan will identify the purpose for which the Personal Information is required in a way that you can reasonably understand how that information will be used, distributed or disclosed.
 
2.2 Sigan will only collect, use, distribute and disclose Personal Information of our customers for the following business reasons:
 
2.2.1 to place order with Sigan;
2.2.2 to process orders;
2.2.3 to keep track of your order preferences;
2.2.4 to organize, streamline and speed up the ordering process;
2.2.5 to investigate service related issues of Sigan and Third Parties;
2.2.6 to develop, improve, market or provide additional products and services;
2.2.7 to manage and develop the business and operations of Sigan, including employment matters;
2.2.8 to meet legal and regulatory requirements.
 
2.3 Sigan may sell, transfer and disclose your Personal Information as part of a sale, merger, joint-venture, assignment, transfer, reorganization, or acquisition of all or a part of our business assets or stock of Sigan or any of our businesses.  Personal Information about our customers and other information we have collected as described in this Privacy Policy may be among the transferred business assets and may be shared with other parties.
  
2.4 If Sigan intends to use Personal Information for a purpose other than what was identified at the time the personal information was collected, then we will obtain the prior consent of the individual to that additional use unless it is for a situation where consent can be implied through your actions with us.
 
2.5 When you visit our Website, certain information about your visit may be collected automatically even if you do nothing during your visit but browse through the information contained on the Website.  Information collected will not identify you personally but may include the following: internet domain, time of access, duration of access, webpages accessed, IP address of the computer used to access our Website, MAC address, computer type, screen resolution, operating system and version, pixel tags, cookies, web beacons, features used, hyperlinks selected, browser type and confirmation of receipt or review of emails (“Tracking Information”) from Sigan.
   
2.6 Sigan may also use "cookies" to improve or personalize Website service and speed by recalling your previous visit to our Website.  These cookies may enable you to use certain Website features, store preferences and recognize you when you visit our Website.
   
2.7 Our Website may offer advertising which is tailored to your interests.  To provide this advertising Sigan works with Third Parties that may use Tracking Information.  Tracking Information may be collected and used to determine which ads you see on our Website or third-party websites and to determine the effectiveness of our Website and advertising.  You may configure your internet browser to limit or stop the use of cookies and Tracking Information however doing so may limit your ability to use the Website and services.  The information may be used to improve the Website, personalize user features, determine preferences and tailor our communications with you.  Cookies do not contain Personal Information and Sigan does do not exchange cookies with any third party websites or external data suppliers.  We will only keep cookies for the duration of your visit to our Website, except where you save your login information.
 
2.8 When you visit our Website, place an order personally with one of our representatives or by phone, save your information on your Website or contact us with questions or concerns, we may collect Personal Information from you.  We also maintain a record of your order history and the types of products and services that you or your company may offer. We may combine this with Personal Information about you that we acquire from our joint marketing partners or from unrelated third parties. 
 
2.9 Where a password is used to access pages within our Website, you are responsible for keeping your password confidential and it is strongly suggested that your Sigan password or account is not shared with anyone.
 
3.0      Consent
 
3.1 Personal Information will only be collected, used, or disclosed with your knowledge and consent, except where inappropriate.  Personal information may be collected, used, or disclosed without your knowledge or consent where permitted or required by law such as where collection or use is undoubtedly in the interests of the individual and consent cannot be obtained in a timely manner, in cases of emergency or for debt collection.
 
3.2 Consent may be express (oral, written or electronic) or implied and will depend on the sensitivity of the information and the reasonable expectations of the individual.
  
3.3 Implied consent may occur where an individual chooses to place an order through with one of our representatives or over the phone.
 
3.4 Consent may also be withdrawn, subject to reasonable notice and legal restrictions.  If you have submitted Personal Information and later wish to withdraw consent to its retention, use or disclosure, you should contact the Privacy Officer as indicated in Section 10.
 
3.5 Without consent, Sigan may not be able to provide the products or services requested.  We will inform you of any implications when you withdraw consent.
 
3.6 Products and services are only conditional upon consent to the collection, use, or disclosure of Personal Information that is necessary to provide such products or services.
 
3.7 Consent for the use or disclosure of Personal Information will usually be obtained at the time of collection but may be sought after Personal Information has been collected (but before use) such as where Sigan has requested permission to use personal information that has already been collected for purpose(s) not previously identified.
 
3.8 Where you provide Sigan with Personal Information we assume you have consented to the collection, use and disclosure of such information so long as it is not inconsistent with this Privacy Policy.
 
3.9 We may also seek your consent to share Personal Information with Third Parties and where you provide such consent, these Third Parties may use your Personal Information in order to let you know about goods and services which may be of interest to you.
 
4.0      Limiting Collection
 
4.1 Sigan will only collect the amount and type of Personal Information which is necessary for our identified purposes and we will only collect Personal Information by fair and lawful means.
 
4.2 Personal Information includes your name, address, telephone number, email address, debit card and/or credit card information, postal code, city/town, order history and any and all other information that may be obtained based on the information you submit when you place an order personally with one of our representatives or by phone.
 
4.3 Non-personal information is information that does not identify you such as aggregate information to help determine demographic data.
 
5.0      Limiting Use, Disclosure, and Retention
 
5.1 Sigan always uses contractual or other safeguards to ensure protection of Personal Information and Personal Information will be used and disclosed only for the purpose for which it was collected or as required by law, except with the consent of the individual.
 
5.2 When Personal Information is no longer required to fulfill the purpose for which it was collected, it will be destroyed, erased or made anonymous, provided there are no legal requirements for its continued retention should the same be possible.
 
5.3 Access to Personal Information is limited to Sigan employees with a business need to know and Third Parties who require access for business purposes.
 
5.4 From time to time, Sigan will disclose Personal Information to others, including to affiliated entities or unrelated companies ("Third Party Service Providers") that carry out certain responsibilities on behalf of Sigan.  Responsibilities include but are not limited to: placing or fulfilling an order, promotions, surveys, business administration, communications, processing payment, data processing or investigation of potentially fraudulent or suspicious transactions.  Sigan takes necessary steps to ensure that the Third Party Service Providers do not use or disclose Personal Information for any purpose other than the specific purpose requested.
  
Some Third Party Service Providers may be located outside of Canada, including in the United States, and Personal Information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for purposes described in this Privacy Policy.  If Personal Information is located outside Canada it will be subject to legal requirements in such foreign countries as applicable to the Third Party Service Providers, such as the requirement to disclose Personal Information to foreign governments.
 
6.0      Accuracy
 
6.1 Sigan will take all reasonable efforts to ensure that Personal Information is accurate, complete, and up-to-date in relation to the purposes for which the Personal Information is to be used.
  
7.0     Safeguards
 
7.1 Personal Information will be protected with safeguards appropriate to the sensitivity of the information.
 
7.2 Sigan makes all employees aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from unauthorized access.
 
7.3 Sigan has safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held.
 
7.4 Personal Information will be safeguarded by physical measures (locking filing cabinets, restricting access to offices), organizational measures (employee training, limiting access on a necessity basis) and technological measures (Secure Sockets Layer (SSL) technology passwords, firewalls and encryption).
 
7.5 Sigan stores Personal Information provided to us in our electronic databases. It is possible that some of our electronic databases may be located outside of Canada, including in the United States, and will be subject to legal requirements in such foreign countries as applicable to the Third Party Service Providers, such as the requirement to disclose Personal Information to foreign governments.
 
7.6 Sigan maintains Personal Information in a combination of paper and electronic format.  General business records are stored in files kept onsite at our Toronto office.  Some records, including older records, may be stored at an offsite storage facility, in either paper or electronic format. Where records are stored with off-site storage facilities, Sigan uses contractual or other means to ensure that your privacy rights are protected.  Email records are also stored in an electronic format which may be located outside of Canada, including the United States.  As a result, your Personal Information may be subject to legal requirements of foreign countries as applicable, such as the requirement to disclose Personal Information to foreign governments.
 
7.7 Although we have enacted various security measures, Sigan cannot guarantee the absolute security of our Website or the security of information that you submit (or that we send to you) over the internet, since no internet transmission absolutely secure or error-free. Your use of the internet and electronic mail is at your own risk.  Please do not send us sensitive information through electronic mail.  If you have reason to believe that your information stored with us is no longer secure, you must immediately notify us of the problem by contacting us as set out on our Website.
 
8.0      Openness
 
8.1 Information about our policies and procedures relating to Personal Information will be readily available to individuals, including information on how to gain access to Personal Information, the type of Personal Information held by Sigan and/or transferred to Third Parties or Third Party Service Providers, including a general account of its use and how to contact our Privacy Officer.
 
9.0      Individual Access
 
9.1 Access to Personal Information, including how we use and disclose the Personal Information may be obtained on written request. An individual can challenge the accuracy and completeness of their Personal Information and have it amended as appropriate.
 
9.2 An individual’s written request for access to Personal Information will be answered within a reasonable time and at a reasonable cost.  We will assist any individual who informs us that they need assistance in preparing a written request and we may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of Personal Information.  Any such identifying information shall be used only for this purpose.
 
9.3 If an individual successfully establishes the inaccuracy or incompleteness of Personal Information such Personal Information will be amended to ensure that it is accurate.  If a challenge to the accuracy of Personal Information is not resolved to the satisfaction of the individual, we will document the content of the challenge. The amended Personal Information or the existence of the unresolved challenge, as the case may be, may be transmitted to Third Parties or Third Party Service Providers having access to the information in question.
 
9.4 Requests for access to Personal Information we hold about an individual may be refused if permitted or required by law.  In such a case, the reasons for denying access will be provided to the individual upon request which reasons may include: information that contains references to other individuals or contains confidential commercial information which cannot be redacted from the file; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.
 
10.0   Questions and Complaints
 
10.1 Any questions regarding this Privacy Policy, practices relating to Personal Information held by Sigan, or any challenges concerning our compliance with this Privacy Policy should be sent in writing to our Privacy Officer:
 
Privacy Officer – Sigan Industries Group
Facsimile: 
E-mail:
 
10.2 All written complaints will be investigated and if Sigan determines a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our Privacy Policy, policies and/or practices.  A complainant will be advised of the outcome of the investigation regarding their complaint.
 
10.3 We encourage the use of our internal information and resolution process to resolve a complaint however an individual may also seek advice from the Office of the Privacy Commissioner of Canada at 1.800.282.1376 or info@privcom.gc.ca and, if appropriate, file written complaint with that office.
 
11.0   Updates to this Privacy Policy
 
11.1 Sigan reserves the right to make changes to this Privacy Policy.  If this Privacy Policy materially changes, Sigan will take reasonable measures to notify you of these changes, including posting a copy of the revised Privacy Policy on our Website.  Your continued consent to our collection, use and disclosure practices following notification of any material change and/or your continued access to our Website following the posting of any changes to this Privacy Policy shall constitute your acceptance of such changes. 
 
12.0   Unsubscribe
 
12.1 Sigan will communicate with you only if you want to hear from us.  If you prefer not to receive promotional information, such as information about special offers, you can let us know by following the "opt out" instructions provided in promotional electronic mail sent to you.
 
12.2 If you ask us to remove your name and address from our promotional lists, we will maintain your name in a "do not contact" file in order to honor your request.  It may take up to eight (8) weeks to process your request, during which period you may continue to receive communications from Sigan.
 
Last Updated: June 19, 2013
 
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