1. About Your Privacy
(2) "Personal Information" is defined in Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and similarly in certain provincial privacy legislation, as information about an identifiable individual, though it does not include the name, business title, business address or telephone number of employees of organizations.
2. Our Ten Privacy Principles
(1) Conagra Brands is committed to collecting, using and disclosing your personal information and maintaining the accuracy, confidentiality and security of your personal information, only in accordance with PIPEDA and similar provincial privacy legislation. As part of this commitment, we have adopted the following ten principles, based on the values set by the Canadian Standards Association's Model Code for the Protection of Personal Information and Canada's PIPEDA.
(a) Accountability: Conagra Brands is responsible for maintaining and protecting the personal information under its control and shall designate one or more individuals to be accountable for compliance with these principles, including a Privacy Officer.
(b) Identifying Purposes: The purposes for which personal information is collected shall be identified before or at the time the personal information is collected.
(c) Consent: Individual's consent will be obtained for the collection, use or disclosure of personal information, except where the law provides an exemption.
(d) Limiting Collection: The personal information we collect shall be limited only to that which is necessary for the purposes identified.
(e) Limiting Use, Disclosure and Retention: Personal information shall only be used or disclosed for the purposes for which it was collected, unless an individual has otherwise consented or when it is required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
(f) Accuracy: We shall keep personal information as accurate, complete and up-to-date as may be necessary to fulfill the purposes for which it is to be used.
(g) Safeguards: We shall protect personal information using security safeguards that are appropriate to the sensitivity level of the personal information received.
(h) Openness: Conagra Brands will provide information to individuals about our policies and procedures relating to the management of personal information that is under our control.
(i) Individual's Access: On written request to our Privacy Officer, an individual will be informed of the existence, use and disclosure of their personal information that is under our control, and may be given access to that personal information as required and permitted by law. Individuals are entitled to challenge the accuracy and completeness of that personal information and request that it be amended, if appropriate.
(j) Handling Enquiries or Complaints: Any questions or enquiries concerning compliance with our privacy policies and procedures may be addressed to our Privacy Officer, as set out below.
3. Why We Collect and Use Personal Information
(1) Conagra Brands collects personally identifiable information from visitors to our sites solely on a voluntary basis and only such personal information as is required to fulfill the purposes set out below. Such personally identifiable information may include your name, postal address, e-mail address, company name and/or telephone numbers, etc. Only those employees at Conagra Brands who require your personal information will have access to it.
(2) Conagra Brands collects personal information primarily for the following reasons: (a) to respond to customer inquiries;
(b) in connection with considering and evaluating applications for employment e-mailed to Conagra Brands;
(c) to e-mail consumers with updates and news;
(d) to notify winners of contests, games and sweepstakes, and to distribute associated prizes;
(e) to send out brochures, etc. via regular mail to subscribers;
(f) to distribute items that are part of "give aways" that you have registered for; and
(g) for use in our online and off-line marketing and advertising campaigns.
(3) Personal information may also be used for other purposes, subject to obtaining your prior consent for such use.
(4) Aggregate Information: There may be times when we share aggregate information about our users (for example, the % of male and female visitors to our sites), with advertisers, business partners, sponsors, and other third parties in an effort to customize or enhance the content and advertising on our sites for our users, but only in a way that does not permit any user to be identified.
(5) Contests/Sweepstakes: We periodically run contests and sweepstakes on our sites for which we ask users/participants to provide contact information (like their e-mail address). This information is used to contact the participant only when necessary in accordance with the rules of the contest or sweepstakes. If a participant has indicated upon entering a contest or sweepstakes that he/she is under 13 years of age, the participant is instructed to enter the e-mail address of his/her parent or guardian. Further, for any game or contest where the screen names of participants are posted, a user under 13 can only select a generic screen name from a list that has been developed in advance, preventing the disclosure to third parties of any personally identifiable information. When a participant under the age of majority in the province or territory of his or her residence is selected as a prize-winner in a contest or sweepstakes, an e-mail is sent to the parent or guardian. This e-mail contains a form that requests the participant's real name and address and a parental permission form. In order for the participant to receive the prize, the parent or guardian must fill out and sign the form and then mail or fax it to the address or number indicated on the form.
(6) Polls & Surveys: Information gathered from polls and surveys are only for internal use of Conagra Brands. If sample answers to polls or surveys are posted on the web site, then no identifiable Personal Information is ever included.
(7) Choice/Opt-out: Our sites will provide users the opportunity to opt out of receiving communications from us at the point where we request information about the visitor. Simply follow the procedure outlined at each site. Likewise, we will provide users with the opportunity to change any personal information previously provided, or to opt out of receiving future email communication from us.
4. Consent To Use Personal Information
(1) Consent may be obtained in various ways. We may obtain your express consent or we may determine that consent has been implied by the circumstances. Express consent could be in writing (for example in a signed consent, e-mail or application form), or verbally in person or over the telephone. When we receive personal information from you that enables us to provide you with a requested product or service, your consent to allow us to deal with that personal information in a reasonable manner would be implied. If you need to provide personal information about other individuals (such as dependants), you must first obtain their consent for these purposes prior to your disclosure to us.
(2) Providing us with your personal information is always your choice. When you request services from us, we ask that you provide information that enables us to respond to your request. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for these purposes. You also authorize us to use and retain this personal information for as long as it may be required for the purposes described above. Your consent remains valid unless you provide us with written notice that such consent is withdrawn.
(3) There are legal exceptions where we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. For example, an exception would apply if there is an emergency that threatens the life, health or security of an individual, or if we must comply with a court order.
(4) Children: We recognize there are unique issues raised about the protection of our children's privacy over the Internet. All Conagra Brands web sites are designed to comply with the requirements of the PIPEDA and all applicable provincial privacy legislation for web sites gathering identifiable information from individuals and particularly from children. In particular, with respect to personal information collected from children we would advise that we distinguish between "off-line" and "on-line" contact information. We would also advise that, consistent with these requirements and guidelines, and provided that we have been given accurate information by the child when asked, we do NOT:
(a) collect personally identifiable off-line contact information from children under 13 without prior parental consent;
(b) distribute to third parties any personally identifiable information of a child without prior parental consent;
(c) entice children by the prospect of a special game, prize or other activity, to divulge more information than is needed to participate in the activity;
(d) use or disclose on-line contact information without prior parental consent;
(e) collect on-line contact information from children other than in connection with on-line contests and sweepstakes;
or (f) enable children to publicly post or otherwise distribute personally identifiable contact information without prior parental consent.
As with those whose personal information has been collected, parents can always ask to review any personal information about their child that has been collected at one of our sites, have us delete any such personal information, and/or instruct us not to collect or use such personal information about their child in the future. To do so, simply contact us following the procedure outlined below in "How To Contact Us".
5. Sharing Personal Information With Others
(1) We are not in the business of selling client lists or personal information to others. In providing our services, we may need to disclose the personal information we collect to affiliates, subsidiaries, successors and other service providers or agents who perform various functions for us. When we have your consent to collect, use or disclose personal information, this consent extends to the disclosure of your information to these others for the purpose of providing these various functions for us.
(2) We will never sell, transfer, or disclose any personal information we gather at our web sites to any third parties without your prior consent, except in cases when we believe in good faith that we have a legal obligation to disclose such personal information or where the law permits us to disclose. We never require that this personal information be provided in order to gain access to our sites.
(3) In certain circumstances, we may be required to provide personal information to third parties for legal or regulatory purposes.
(4) We may also use this personal information to assess your future needs and to offer the products and services that may best meet those needs, from ourselves or our affiliates.
6. Keeping Information Accurate
(1) It is important that your personal information is accurate and complete. Having accurate information about you enables us to give you the best possible service. You have the right to access, verify and amend the information we have about you. We rely on you to keep us informed of any changes, such as a change of address, telephone number or any other circumstances - simply contact us at firstname.lastname@example.org.
(2) Despite our best efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know and we will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from us.
(3) You have the right to access the personal information which Conagra Brands has collected about you at any time and rectify such information if it contains any errors. In order to exercise your right of access, please contact Conagra Brands' Privacy Officer (see below).
7. How We Safeguard Personal Information
(1) At Conagra Brands, we employ physical, electronic and procedural safeguards to protect our systems and all personal information under our control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected. The personal information collected and stored by Conagra Brands may be stored on systems located outside of Canada.
(2) Our service providers and agents are required to maintain confidentiality with respect to all personal information, and may not use the information for any unauthorized purpose.
(3) Employees are governed by standards and policies to ensure that personal information is secure and treated with the utmost care and respect.
8. Privacy and the Internet
(1) Conagra Brands may collect user information from its Web sites (for example, via cookies which are alphanumeric identifiers transmitted from a Web site to a visitor's browser and IP address). This information is used solely for enabling us to provide you with a customized online experience and to find ways to improve our site (including by helping diagnose problems with our web server). Although cookies are widely used, it may be possible to disable cookies via your browser settings. However, in so doing, some Web sites may not function properly or optimally.
(2) The cookies Conagra Brands uses do not contain any personally identifying information and cannot profile your system or collect information from your hard drive. You are not identified by name or e-mail address, just by a unique string of numbers that we assign the first time you come to our site.
9. How to Contact Us
You may also contact us by mail as follows:
Attn: Privacy Officer
5055 Satellite Drive, Unit 1 and 2
Mississauga, Ontario L4W 5K7