Privacy Policy
This Privacy Policy is current as of January 23, 2024, and describes:
our practices in connection with the information we collect from you when you visit our websites that link to this Privacy Policy (the “Site”), or when you use any applications made available by us on or through computers and mobile devices (the “Apps”),
when we communicate with you through e-mail messages that link to this Privacy Policy (collectively, including the Site and Apps, referred to as the “Services”);
our privacy practices when we communicate with you by offline channels, such as when you provide your information via phone, or in person (“Offline Services”); and
the basis on which we will process personal data we collect from you or that you provide to us, and your choices with respect to that data.
This Privacy Policy excludes those websites and online services that have separate privacy policies and do not incorporate this Privacy Policy by reference or otherwise. Our privacy practices may be more or less limited in certain countries in which we operate to reflect local practices and legal requirements. We will specifically inform you, if this is the case.
By providing your personal data and other information through our Services, you acknowledge that your personal data will be processed pursuant to the terms of this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use the Services or provide any personal data.
Information that Two Happy Feet Collects
When Personal Data is Collected
Why Personal Data is Used
When Personal Data is Disclosed
Cookies and Other Technologies that Two Happy Feet Collects
How We Protect Your Personal Data
Third-Party Websites and Services
How Long Personal is Data Retained
Managing Your References and Information
Your Rights Regarding Your Personal Data
Collecting Information from Children
Policy Modifications
How to Contact Us
1. Information that Two Happy Feet Collects
1.1 Personal Data
The term “Personal Data” as used in this Privacy Policy refers to any information relating to an identified or identifiable individual, or as defined under applicable law. We collect Personal Data such as:
Your name, e-mail address, phone number, physical address (billing and shipping), title;
Demographic information and location, and government-issued identifiers;
Your credit card and/or debit card details;
Information, feedback or content you provide regarding your marketing preferences, in surveys, comment cards;
Other types of information that you voluntarily choose to provide to us.
1.2 Sensitive Personal Data
From time to time, you may provide or we may collect what is considered sensitive personal information or “special categories of personal data” under applicable privacy laws (herein referred to as “Sensitive Personal Data”).
We only process Sensitive Personal Data if and to the extent permitted and required by applicable law or with your express consent. Unless otherwise required by applicable law, you are not required to provide us with any of your Sensitive Personal Data. Should you choose not to, your decision would not prevent you from using our Services.
2. When Personal Data is Collected
We collect Personal Data about you in a number of ways, including:
When you book an appointment or submit a contact form. Visitors who elect to book appointments using our booking form or over the phone will be asked to supply specific Personal Data, including name, email address and contact information. We collect your Personal Data to provide you with services, including when you purchase goods and services, and when you book a consultation or service.
When you provide your comments and feedback or communicate with us. We may collect Personal Data that you voluntarily share with us in surveys and feedback. We also collect your Personal Data when you communicate with us via text or email or otherwise, such as through WhatsApp.
3. Why Personal Data is Used
We use your Personal Data in a number of ways as set forth below.
3.1 Performance of a Contract. We process your Personal Data in order to perform a contract with you, including to complete your booking, provide you goods and services that you requested, or to follow up on treatment when necessary.
3.2 Legitimate Business Reasons. We use your Personal Data where it has a legitimate business reason to do so. This includes providing you with superior customer service and a personalised experience, keeping our Services safe and secure and to protect our operations or those of any of our affiliates or other third parties, and distributing and responding to surveys regarding your experience. Such legitimate business reasons also include providing you with information that you have requested and responding to your inquiries, anonymizing Personal Data provided under this Privacy Policy to improve Services and guiding the development of new features and services, and subject to applicable law and regulations, in the event of a corporate event such as a sale, merger or change in control.
3.3 To Comply with Legal Obligations. We process your Personal Data where it is necessary to comply with legal obligations to which it may be bound. This includes complying with legal processes, responding to requests from public and government authorities around the world, and pursuing available remedies or limiting damage we or other third parties may sustain.
3.4 With Your Consent. We process your Personal Data when we have your valid consent to do so, including to communicate (including by email and SMS) with you, to send you follow-up information, newsletters, information about our Services, and other marketing communications in accordance with your preferences; and to process Sensitive Personal Data you may have provided in connection with your treatment; for example, any special accommodations for physical and medical conditions.
3.5 Vital Interest. In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to process your Personal Data, including Sensitive Personal Data you provided through our Services, where it is in your vital interest or in the interest of others, for example in the event of a medical emergency.
3.6 We will not sell, rent, or share your information without your consent except in accordance with this Privacy Policy or for the purposes disclosed on any online form or location on the Services where you provide Personal Data to us.
4. When Personal Data is Disclosed
We may disclose or share your Personal Data as follows:
4.1 Commercial Service Providers and Suppliers. We may outsource the processing of certain functions and/or information to third parties that provide services such as Services hosting, data analysis, payment and credit card processing, order fulfilment, customer service, email delivery, financial services companies, delivery services, advertising networks, and information technology.
4.2 External Partners. We may share your Personal Data to other partners, consultants and advisors who render services to us, including financial institutions, external auditors, lawyers, and credit card issuers.
4.3 Anonymized Data. We may share aggregated data with third parties collectively in an anonymous way, which does not reveal Personal Data.
4.4 Legal Obligation. If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, pursuant to a legal request, subpoena or other legal processes, or in order to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or our safety, our guests, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Cookies and Other Technologies that Two Happy Feet Collects
5.1 Automatic Data Collection. We may use automatic data collection technologies to collect certain statistical (non-personal) information about your equipment, browsing actions, and patterns, including (a) details of your visits to our Services, including traffic data and location data, date and time of access, frequency and other communication data; (b) information about your computer and internet connection, including your IP address, operating system, host domain, and browser type; and (c) details of referring websites actions, and patterns.
5.2 Cookies. As further described in our Cookie Policy, we use cookies and other similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on or across different Services and devices. We also allow other third parties to use cookies as described in our Cookie Policy; You can control cookies through your browser settings and other tools. For more information on the cookies we collect and how to disable them, please visit our Cookie Policy.
5.3 Do Not Track. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.
6. How We Protect Your Personal Data
We maintain commercially reasonable security safeguards that are designed to protect the Personal Data we collect against unauthorised use, disclosure, alteration or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee or warrant that your Personal Data is under absolute security with the existing security technology. Additionally, when requesting information or sending information or forms to us by email, please be advised that e-mail communication to and from our Services are not secure unless clearly noted otherwise. This is a risk inherent in the use of email.
7. Third-Party Websites and Services
This Privacy Policy only addresses the collection, use, and disclosure of information by us through your interaction with our Services. This Privacy Policy does not address the policies or practices of any third parties or any third-party websites or features that are linked to or available from our Services. If you provide any information to any other third parties, different rules regarding the collection and use of your Personal Data by such third parties may apply. Please contact these entities directly if you have any questions about their privacy practices.
8. How Long Personal is Data Retained
9.1 We retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law. Note that we may need to retain certain information for recordkeeping purposes and/or to complete transactions (e.g., when you make a purchase or booking), and you may not be able to change or delete the Personal Data you provided until after completion of such purchase or reservation.
9. Managing Your References and Information
9.1 Commercial E-mails. You may opt-out of receiving commercial emails from us by following the instructions contained in any of the commercial emails. Unsubscribing from one type of communication may not unsubscribe you from another type. Please note that even if you unsubscribe from commercial email messages, we may still email you non-commercial (transactional) emails related to your account and your transactions via the Services.
9.2 Text Messages and SMS. To opt out of text messages, reply STOP to the message you received or contact us to inform us you no longer wish to receive text messages.
9.3 Mobile Apps. You can control whether our Apps send you push notifications by changing your notification settings on your mobile device.
9.4 Access and Connections to Social Media. If you registered with the Services through your social media account, or connected, linked, or shared your use of our Services via your social media profile, you can manage the permissions granted to such third-party social media services by accessing your user settings under your account. You also can remove our access to your social media account or otherwise control what information these third-party social media services share with us at any time by accessing the privacy settings in your social media account.
10. Your Rights Regarding Your Personal Data
Under applicable law and regulations, you may, at any time, exercise certain rights, including the following:
10.1 Access. The right to request access to your Personal Data, which includes the right to obtain confirmation from us as to whether Personal Data concerning you is being processed, and where that is the case, access to the Personal Data and information related to how it is processed.
10.2 Rectify or Erase. The right to rectification or erasure of your Personal Data, which includes the right to have incomplete Personal Data completed.
10.3 Restrict. The right to obtain a restriction of processing concerning your Personal Data, which includes restricting us from continuing to process your Personal Data under certain circumstances (e.g., where you contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of the personal data).
10.4 Object. The right to object to the processing of your Personal Data under certain circumstances, including objecting to processing your Personal Data for direct marketing purposes, or objecting to processing your Personal Data when it is done based upon legitimate interests.
10.5 Data Portability. The right to data portability, which includes certain rights to have your Personal Data transmitted from us to you or another controller.
10.6 Consent. Where we process your Personal Data based on your consent, the right to withdraw consent at any time with effect for the future. Any requests related to the above rights may be made by contacting us as set forth in Section 13.
10.7 Complaint. In some jurisdictions, you may also have the right to lodge a complaint with a supervisory authority.
10.8 Privacy Rights for California Residents. Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of personal customer information we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year. That notice will identify the categories of information shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you are a California resident and would like to request a copy of this notice, please submit a written request to Two Happy Feet, 2846 Colquitz Ave., Victoria, British Columbia, V9A 2M1.
11. Collecting Information from Children
Should we inadvertently acquire Personal Data or other information from users under the age of 16, we will not knowingly provide this data to any third party for any purpose. If a child does provide us with Personal Data over Services, a parent or guardian of that child may contact us and upon notification, we will delete from our records any information collected from children under the age of 16.
12. Policy Modifications
We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your Personal Data, we will notify you through a notice on the Services home page. The date this Privacy Policy was last revised is identified at the top of the page. It is your responsibility to ensure that we have a deliverable email address for you, and for you to periodically monitor and review any updates to this Privacy Policy. Your continued use of our Services after such amendments will be deemed your acknowledgement of these changes to this Privacy Policy.
13. How to Contact Us
If you have any questions or comments about our privacy practices or this Privacy Policy, please contact us by email at info@twohappyfeet.ca or by mail at:
Two Happy Feet
2846 Colquitz Avenue
Victoria, BC
V9A 2M1