Privacy Policy

Last Updated: June 17, 2021

1. Who we are

Ddrops Company manufactures supplements and health products. It was founded in response to a need for a simply better way to provide vitamin D. Ddrops Company research and development is geared toward developing and marketing effective, convenient and high-quality supplements under the Ddrops^® brand. Ddrops Company also offers additional information and helpful answers to frequently asked questions.

Ddrops Company is a company incorporated in Canada with a registered office at 126 Trowers Road, Woodbridge, Ontario L4L 5Z4, Canada.

This Privacy Policy reflects the EU General Data Protection Regulation, the UK’s Data Protection Act 2018 (collectively we will call them the “European Data Protection Laws”) and other applicable laws, and applies to all Ddrops Company activities and initiatives, including:

• Ddrops Company website, including blog articles
• Ddrops Company interactions with consumers, healthcare professionals, and business partners
• Ddrops Company activity and participation at events, meetings and conferences
• Information you provide to us through other Ddrops activities or platforms, including social media activity and contests
• Ddrops Company surveys and questionnaires
• Purchases made on Ddrops Company Amazon Storefront

2. Purpose

This Privacy Policy outlines the privacy practices of Ddrops Company (“Ddrops Company”, “we”, “our”, or “us”). This Privacy Policy explains when and why we collect personal information, for example, about people who interact with us at trade shows, visit our website, or otherwise provide us with personal information. It explains how we use this information, the conditions under which we may disclose it to others, and how we keep it secure.

Ddrops Company is a “controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Policy. Whether through this Privacy Policy or otherwise, we aim to provide a good understanding of why and where we process personal information and the rights our visitors have.

3. The Information We Collect

The types of personal information we may collect includes:

• your first name, shipping city, province/state, postal code and country, and email address,
• product details including purchase date and time and purchase amount,
• in the event of an adverse reaction, information about your reaction and the context such as the product you used and the reaction you experienced, your name, address, telephone number, email address and any personal information that you share, such as allergies;
• for business reseller accounts, we may collect the first and last name of the company representative as well as their business email address,
• for Healthcare tradeshow attendees – your registration information that was scanned at our booth with your permission, including name, designation, practice information, mailing address, email address, telephone and fax number and any other information that you provided,
• for Healthcare Practitioners – your name, company’s/employer’s name, mailing address, email address, telephone and fax number,
• for Healthcare Practitioners – your professional designation and information regarding your practice,
• for Healthcare Practitioners samples and materials requested and the frequency of your requests, and
• your product return history, and other personal information that you choose to provide to us, for example, if you complete a survey, participate in an offer or promotion, post a product review, submit a resume, or call or write to us, or speak to any chat function we make available on our website.

Ddrops Company collects information by various methods including:

• Sales from Ddrops Company Amazon store front,
• Application forms and other information requests,
• Information actively provided by its lead providers (for example, if we purchase or rent a contact list) and its customers,
• Information arising from customer surveys and general feedback,
• Contact information at events and conferences,
• Email, telephone, and written correspondence,
• Our social media pages,
• If you use any ‘chat’ feature enabled on our websites, and
• We record calls to our sales/customer service representatives for purposes of accuracy, performance reviews, training, to protect our and your interests, and for general quality assurance, if you give your prior consent, which you may give by remaining on the call after having been informed of the recording.

If you purchase products from us via third party retailers, for example, through our Amazon storefront, we may have access to the following personal information about you and your order from these third parties if you make an inquiry, request or complaint about your order: name, shipping address information, products ordered, and order details, order history, card type, last 4 digits and expiration and name on credit or debit card. We use this information to help respond to your inquiry, request or complaint.

To learn how we collect information through automatic means, please view our Cookie Policy.

4. How we use the Information We Collect

We may use the personal information we collect for various purposes, including:

• To understand your interests, needs and preferences, build a profile about you and respond to your requests and settle any complaints or inquiries you may have,
• We use information about your purchase of our products in order to manage any inquiries you may have regarding your purchase (i.e., process orders, track and complete purchase, shipment, returns or missing product, etc.),
• Subject to your right to opt-out (please see our Cookies Policy (link)), to tailor advertising to you by delivering to you or allowing you to see certain advertising based on your interests, searches you perform, information you provide on our website, and your activity on our websites or other websites,
• Subject to your right to withdraw consent for such purposes, and where required by law, with your consent, to communicate with you about products, services, special events or offerings, including on behalf of us or third parties, including by email or other methods (e.g., direct mail). If you receive commercial email from us, you may opt-out using the ‘unsubscribe’ function in such email,
• If you are a health care professional and wish to participate in our sampling program, we use the information you provide to assess whether you are eligible for the program. If you are approved, you are provided with access to the program. Your information helps our team understand your need for samples, product information, as well as provide you with appropriate advertising based on our understanding of your practice,
• If you apply for employment with us, we use the information you provide, such as your resume, to evaluate you for employment, and if we offer you a position, to establish and manage the employment relationship. We may retain this information to assess you for future positions if they become available,
• To conduct surveys, sweepstakes, contests and promotions, as well as research and statistical analysis,
• To customize your experience on the Site or to serve you specific content or ads that we believe is relevant to you,
• To monitor communications to ensure the consistency, quality and accuracy of our customer service, and our products and services. If you call our call centre, we may record your call for this purpose,
• To measure and analyze audience traffic, improve the website, marketing endeavors or our product and service offerings,
• To manage and develop our businesses and operations,
• To notify you of any product recalls or providing other information concerning products or services you have purchased,
• To identify you as a customer and to identify your product and service preferences, including providing personalized content and ads and informing you of new or additional products, services or promotions that may be of interest to you,
• To detect and protect us and other third parties against error, negligence, breach of contract, theft, fraud and other illegal activity,
• For internal business purposes,
• To carry out other purposes that are disclosed to you and to which you consent, and
• To carry out any other purpose permitted or required by law.

We may use personal information to produce anonymous, non-identifiable information, and to use or disclose such non-identifiable information in any way that we deem appropriate.

5. Cookies and Other Tracking Technologies

Ddrops Company uses cookies and other tracking technologies to collect information when you visit our website and social media posts.

For more information about cookies, tracking and how we use tracking technologies on our website please visit our Cookie Policy.

You may see certain ads on our website as well as on other third-party websites across the Internet because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites by collecting information through automated means, including through the use of the tracking technologies described elsewhere in this Privacy Policy, and they use this information to show you advertisements (including our ads) that are tailored to your individual interests.

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Our systems do not monitor or take any action with respect to these browser “Do Not Track” signals or similar mechanisms, but several of the third-party advertising companies that utilize cookies on our websites to provide interest-based advertising enable you to opt out of those practices. For more information, please see our Cookie Policy.

6. Legal Basis For Processing

We may process your personal information on the following legal bases:

Contract. The processing is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal information to us, we will not be able to carry out our obligations under the terms of your contract.

Legal obligation. The processing of your personal information is necessary for the purposes of complying with applicable regulatory, accounting and financial rules and obligations, and to make mandatory disclosures to government bodies and law enforcements.

Legitimate Interests. We are permitted to process your personal information if it is based on our ‘legitimate interests’, where we have good, sensible, practical reasons for processing your personal information, which is in the interests of Ddrops Company. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. In jurisdictions where ‘legitimate interests’ are not a basis on which personal information may be processed, by providing us with personal information for an identified purpose, you consent to our processing it for these purposes. Where personal information are processed based on legitimate interests, e.g., for the purposes of direct marketing, you have the right to object to such processing at any time and free of charge. See the section headed “Your Legal Rights” to find out how. If you object to us processing your personal information, we must demonstrate compelling grounds for continuing to do so.

Consent. Sometimes we want to use your personal information in a way that is entirely optional for you, such as to send you our promotions and news. On these occasions, we will ask for your consent to use your information. You can withdraw this consent at any time.

7. Sharing Information And International Transfers

Ddrops Company will not share personal information with any third parties for the third parties’ use for their direct marketing purposes without your consent. Ddrops Company may use third parties for the purpose of fulfilling your request to receive industry-specific promotions, announcement and other marketing information from Ddrops Company using your personal information that you have provided and to which you have consented.

Ddrops Company may provide personal information to Ddrops Company service providers, vendors subcontractors and professional advisers (who are located in North America, UK or the EU and bound by privacy obligations) to assist us in carrying out the uses of information described in this Privacy Policy.

We may also share your personal information with third parties if we have reason to believe that disclosing such information is necessary to:

• conduct investigations of possible breaches of law,
• identify, contact, or bring legal action against someone who may be violating an agreement they have with us,
• to protect our rights, safety or property, or
• to carry out any other purpose permitted or required by law.

We may also share your personal information when we investigate security breaches or cooperate with government authorities pursuant to a legal matter. We reserve the right to transfer any personal information we have about you in the event that we or the relevant portion of our business, merges with or is acquired by a third party or should any such transaction be proposed.

We may disclose your personal information to another entity purchasing (including, but not limited to, for diligence purposes prior to purchase) the assets of (or otherwise acquiring) Ddrops Company to the extent such disclosure is necessary for the acquisition.

If you inform us of an adverse reaction to one of our products, such as an allergic reaction or other health issue, we may be required to report the matter to health regulatory authorities. We may also contact you to ask you for more information about your experience.

Personal information we collect is maintained with the source of the information at Woodbridge, Ontario and on servers in Montreal, Quebec. The European Commission and the UK Information Commissioner’s Office has recognized Canada (commercial organizations) as providing an adequate level of data protection for the purposes of the Europe Data Protection Laws.
We may also hold your personal information on select third-party cloud-based servers in the United States. This means that some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction of residence and outside the UK and the European Economic Area, including, in the United States and Canada, whose data protection laws may differ from the jurisdiction in which you live. Personal information processed or stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in accordance with the laws of that jurisdiction.

For individuals in the US and Canada, by providing us with personal information, you understand and expressly agree that we may transfer it outside of your jurisdiction. If you do not agree to the transfer of your personal information outside of your jurisdiction, do not provide us with personal information.

In case of the transfer of the information of UK and EU residents to the United States of America, we ensure that the relevant company has entered into a data transfer agreement containing clauses offering an adequate level protection for the purposes of the European Data Protection Laws, has adopted corporate binding rules, or has otherwise implemented appropriate safeguards. In case of Canada, there is an adequacy decision of the European Commission pursuant to Directive 95/46/EC which allows transfers under the European Data Protection Laws. In case of other countries outside the UK and the European Economic Area apart from Canada and the United States and where no adequacy decision for the purposes of the European Data Protection Laws exists, we ensure that the relevant company has entered into a data transfer agreement containing clauses offering an adequate level protection as required under the European Data Protection Laws or has otherwise implemented appropriate safeguards.

Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the processor in that country to maintain protections on the personal information that are consistent to those that apply in Canada and compliant with the requirements under the European Data Protection Laws.

8. Security

Your personal information may be stored in a combination of paper and electronic files. Our security is intended to help protect against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access, and any other unlawful forms of processing. We use technical and organizational measures appropriate to the nature of the information to help protect against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access, and any other unlawful forms of processing. Personal information may be accessed by persons within our organization or our third party service providers or third parties (such as law enforcement), who require such access to carry out the purposes indicated above, or otherwise permitted or required by applicable law.

Although we have taken measures to protect this website, our computer systems, and any personal information that we have collected from unauthorized use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

9. Retention Period

We retain personal information that we collect as long as necessary to fulfill the purposes for which it was collected or to meet any legal requirements. We have retention standards which meet these requirements.

When you, a health care professional, open an account, we will retain your product information and product ordering history for as long as the account is active. When your account is closed we will retain your information in order to continue to communicate with you about our products that may be of interest to you, unless you have opted out of receiving marketing and or newsletter communication or until the period we are allowed to contact you has ended. We may also retain your account information and product history to communicate with you on important business information that may affect you, such as in the unlikely event of a product related issue. This information is retained for a period of up to seven (7) years from the date of your last order shipment.

Health care practitioner tradeshow attendee information is kept for two (2) years and is used as a reference and to evaluate participation at similar tradeshows in the future.

Reseller account applications that have been declined or where the applicant has not been processed, are retained for a period of two years to understand and monitor potentially fraudulent activity – i.e. false account openings in alias’, alternate business names, addresses etc. In these cases, the personal information will be destroyed within 2 years after it has been collected. Other personal information that has been collected, such as account representative information, will be destroyed when the purpose for which it was collected ceases to exist, subject to retention as required by law, including applicable limitation periods.

10. Your Legal Rights

You have rights under data protection laws in relation to your personal information. To help protect against fraudulent requests, and in compliance with the local data protection legislation, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting your request. For example, we may require you to verify your identity before you access your personal information.

You have the right to:

Access your Personal Information. You have a right (subject to limited exceptions under relevant data protection laws) to request access to your personal information. Individuals may send requests to review their personal information contained in Ddrops Company files to the Ddrops Company privacy officer using the contact information provided in the below section, “Company Contact Information/-Privacy Officer”.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no sufficient reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms, as permitted under the local data protection laws. You have an absolute right to object to direct marketing including any profiling of data that is related to direct marketing.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it, as allowed under the local data protection laws.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information, in accordance with the applicable data protection legislation. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. For individuals who reside in the U.S. and Canadian law, if you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact methods and details set out in below section ‘Company Contact Information/Privacy Officer.

11. Your Choices

You have a choice to receive marketing communications from us or not. If you do not want to receive direct marketing communications from us about the products, promotions, information or services we offer then you can select your choices by ticking the relevant boxes or exercising the unsubscribe mechanism situated on emails. You can also change your preferences at any time by contacting us by email at privacy@vitaminddrops.com.

12. Changes To Our Privacy Policy

From time to time we may make changes to our Privacy Policy. By accessing or using this website, or providing us with personal information after such changes, you consent to this Privacy Policy for the purposes of U.S. and Canadian residents only, as revised. We will inform you on our website when changes are made. Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it. The date of the most recent revision will be published on the top of the Privacy Policy web page.

13. Children

Our website is not directed to children, and we do not intend to knowingly collect personal information from any child under thirteen (13). We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). Despite this, if you are the parent or legal guardian of a child under thirteen (13) who has provided us with personal information themselves, you may ask to review or delete this information by contacting us at privacy@vitaminddrops.com.

14. Complaints to the Regulator

You have the right to make a complaint at any time to a supervisory authority in your local jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

15. Links

Ddrops Company website may contain links to information at other websites. When you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites as their privacy policy may differ from ours. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any third party.

16. Company Contact Information/ Data Protection Officer

Ddrops Company is a company incorporated in Canada with a registered office at 126 Trowers Road, Woodbridge, Ontario L4L 5Z4, Canada. For more information on Ddrops Company and privacy, or if you would like to exercise your legal rights, please contact our privacy officer at privacy@vitaminddrops.com, or by writing to 126 Trowers Road, Woodbridge, Ontario L4L 5Z4.

17. Your Nevada Privacy Rights

While we don’t sell your personal information now as defined by Nevada law, Ddrops Company reserves the right to sell personal information to third parties in the future. Nevada S.B.220 allows Nevada residents to opt-out of the sale of their personal information now in the event if we change our policy in the future. If you are a Nevada resident, we want you to know that you have choices and can opt-out of Ddrops Company selling your personal information by contacting us at privacy@vitaminddrops.com. Opting-out may prevent or restrict your use of the website in the future.

18. What About Information I Disclose Publicly?

(a) User Content and Public Information. The website may permit you to share or otherwise submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, information about your location, questions, comments, suggestions or other content including personal information (collectively, “User Content”). We or others may store, display, reproduce, publish, distribute, or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Ddrops Company does not control who will have access to the information that you choose to make public and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the website or what others do with information you share with them on the website. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the website.

(b) Name and Likeness. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the website, please review our website’s Terms & Conditions.

(c) User Testimonials. We often receive testimonials and comments from users who have had positive experiences with our products and services. We occasionally publish such content. When we publish this content, we may identify our users by their social media account usernames and publish their social media account profile pictures.