Our Commitment to You

Entourage Brands Corp. (also "Starseed") takes your privacy seriously. This privacy policy ("Privacy Policy") explains how your personal information is collected, used and disclosed by Starseed.

We are proud of our commitment to the protection of your personal information and to transparency. If you have any questions about our Privacy Policy or any privacy related concerns, please do not hesitate to contact a representative at info@starseed.com

Our Privacy Policy is based on the Canadian Federal Personal Information Protection and Electronic Documents Act as well as the relevant Provincial Acts concerning the collection, use and protection of medical information such as Ontario's Personal Health Information Protection Act.

In order to provide you with products and services, as well as to remain compliant with applicable regulations and laws, Starseed needs to know some of your personal information. You have a right to know how we collect, use, and disclose your personal information and to correct that information if it is wrong. You can rest assured that we will, to the best of our ability, ensure that your personal information held by us remains accurate, confidential, and secure.

How We Collect and Use Your Personal Information

Starseed only collects, uses and discloses personal information for purposes that would be considered reasonable in the circumstances and only such personal information as is required for the purposes of providing our services. Personal information is collected directly from the person concerned, their authorized representatives or from other medical training, licensing, regulatory or credential verification organizations. We use only fair and lawful methods to collect personal information.

Our use of personal information is limited to the purposes described in this Privacy Policy or otherwise identified to you at the time of collection. From time to time, Starseed may require your consent to use your personal information for purposes related to the improvement of our products and services through research studies. For any collection of information not covered in this policy we will request your consent at the time of collection. We do not otherwise sell, trade, barter, exchange or disclose for consideration any personal information we obtain.

Starseed only uses your personal information for the following purposes:

• To process your registration application with us and determine your eligibility for our products and services;
• To verify your medical declaration, your identity and other documentation you provide to us;
• To offer products and services to you and to better understand your need for our products and services;
• To process payment for our products and services;
• To meet our legal and regulatory requirements; and
• Other purposes consistent with these purposes.

Because we value your trust, we will only ask for personal information that we need and, when we ask you for additional personal information, we will let you know why we need it.

When And To Whom We May Disclose or Transfer Your Personal Information

Starseed only collects, uses and discloses personal information for purposes that would be considered reasonable in the circumstances. This may include transfer of your personal information to certain third parties where such personal information is required for the purposes of providing our services, including the transfer of your personal information to your primary care provider, such as your prescribing physician, to facilitate continuity of care and ensure your primary care provider is able to meet its own legally or professionally mandated record-keeping requirements.

Where Starseed transfers personal information to organizations that perform services on its behalf, we will require those service providers to use such personal information solely for the purposes of providing services to Starseed or the person concerned and to have appropriate safeguards for the protection of that personal information.

Starseed may disclose your personal information to:

• Individuals or organizations who are our service providers;
• Individuals or organizations who are involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems;

Please note that there are circumstances where Starseed is permitted or obliged, under applicable privacy legislation, to disclose personal information without consent. Such circumstances include:

• Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
• Where Starseed reasonably believes that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
• Where it is necessary to establish or collect monies owing to Starseed;
• Where it is necessary to permit Starseed to pursue legal remedies or limit any damages that we may sustain; or
• In the event of a corporate amalgamation, reorganization, change of control or sale.
info@starseed.com

A record is kept each time personal information is disclosed, noting the nature of the disclosure, the date and the identity of the party to whom the disclosure was made, provided that individual records of disclosure are not maintained for regular or routine actions such as transfers of personal information to businesses acting as agents of Starseed.

Consent

By providing personal information to Starseed you agree and consent that we may collect, use and disclose your personal information in accordance with this Privacy Policy and any documents that you have executed and/or delivered to Starseed. Except as permitted under applicable privacy legislation, this Privacy Policy or any documents that you have executed and/or delivered to Starseed, we won't collect, use or disclose your personal information without your consent. You can refuse to consent to our collection, use or disclosure of personal information about you, or withdraw your consent to our further collection, use or disclosure of personal information at any time by giving us reasonable notice, provided your refusal or withdrawal of consent does not limit our ability to comply with applicable law with respect to the personal information in our possession or limit any rights we have under this Privacy Policy or any documents that you have executed and/or delivered to Starseed. In certain cases, your refusal to consent could prohibit your eligibility as a client of Starseed.

Unsubscribing

If you do not want Starseed to contact you or share your personal information with other Starseed partners, you may make the necessary arrangements through the Starseed Client Care team, subject to any rights we may have to disclose your personal information under applicable law, this Privacy Policy or any documents that you have executed and/or delivered to Starseed in connection with this Privacy Policy.

Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages such as email. This consent is sought by Entourage Brands Corp. and you can contact us at info@starseed.com or by mail to 250 Elm St, Aylmer, ON N5H 2M8. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message.

Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the products or services we provide to you, or if you contact us with an inquiry.

Changes to This Privacy Policy

From time-to-time Starseed may make changes to this Privacy Policy to better reflect and applicable legislation or best practices, in the normal course of business or to serve you better. You understand and agree that it is your responsibility to periodically check this Privacy Policy for any changes. In the event Starseed makes a significant change to this Privacy Policy, we will use reasonable efforts to draw the changes to your attention.

The Accuracy of Your Personal Information

While Starseed tries to ensure that the personal information we hold about you is accurate, complete and up-to-date, Starseed does not routinely update your personal information, unless required. Therefore, it is your responsibility to inform Starseed promptly of any changes in your personal information. Starseed will, from time to time, verify the personal information that you provide as part of its routine process of client verification or client service. This may include verifying other elements of your personal information with associated stakeholders.

If you believe that personal information in your records may be inaccurate, we make it easy for you to access, verify and update it by submitting a Change of Information form, found here - https://www.starseed.com/application/assets/pdf/COI_form-3.4-en.pdf. If incorrect personal information has been provided to third parties, we will convey the corrected information to them, if necessary.

If we do not agree to change your personal information, you may challenge our decision. We will make a record of this challenge, and if necessary, disclose the challenge to third parties who also possess the personal information.

Retention Of Your Personal Information

We keep your personal information only as long as it is required for the reasons it was collected. The length of time Starseed retains your personal information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with Starseed but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your personal information is no longer required for our purposes, procedures are in place to destroy, delete, erase or convert it into an anonymous form.

We use accredited, secure, off-site digital storage facilities in Canada that do not transmit or store data outside of Canada.

Access to Your Personal Information

Starseed allows you to access and review your personal information held by us. We will respond to a request for access within a reasonable time and generally no later than 30 days following the request.

You can view your information through your online account. To review other personal information that Starseed has about you, simply make a written request to our representative at info@starseed.com. The personal information will be obtained from your records at Starseed and will normally be provided within 30 days of your request. There may be a charge for retrieving a complete list of personal information, in which case you will be notified in advance and you may, at that time, withdraw your request.

If you have a sensory disability, on request, we will give you access to your personal information in an alternative format where available. If it is necessary and if we can reasonably do so, we will convert the personal information into an alternative format.

Sometimes, Starseed will not be able to provide you with your personal information that is within its control. For example, Starseed will not provide you with personal information in its control if:

• It may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions;
• It would disclose personal information, including opinions, about another individual or about a deceased individual;
• It would disclose trade secrets or other business confidential or proprietary information of Starseed;
• It would interfere with contractual or other negotiations of Starseed or a third party;
• It is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
• It does not exist, is not held, or cannot be found by Starseed; or
• It is subject to solicitor-client, litigation or other legal privilege.

If Starseed denies your request for access to personal information, you will be told why, unless we are prohibited by law from doing so. You may challenge that decision.

Once you have the personal information, all you have to do is check it for accuracy and let us know if there are any corrections required. If appropriate supporting documentation is provided, we will correct our records or make note of any differences. If personal information has been provided to third parties, we will convey the corrected information or note any differences to them, if necessary.

The Security of Your Personal Information

Starseed, its staff and our partners are committed to protecting the security of the personal information you choose to share with us. Every Starseed employee, as a condition of employment, takes responsibility for protecting the privacy, confidentiality and security of personal information. This obligation remains in effect even after an employee leaves Starseed. Suppliers of services to Starseed, such as e-commerce and credential verification firms, are required to sign contracts obligating them to protect the privacy and confidentiality of personal information provided to them to enable them to perform their functions.

Starseed also has extensive controls to maintain the security of their operations and information systems, and these controls are tailored to reflect the sensitivity of the personal information. Physical access to those areas where personal information is gathered, processed or stored is restricted to authorized employees.

Appropriate controls are in place over computer systems and data processing procedures and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy policies. Starseed destroys or erases any personal information when it is no longer needed. When personal information is destroyed or erased, Starseed takes care that there is no unauthorized access.

Starseed has appointed representatives on our client care, medical and legal teams who share the responsibility for coordinating overall privacy protection and compliance with this Privacy Policy. You can contact Starseed's Client Care team at info@starseed.com for any privacy related questions or concerns.

Non-Personal Information

Non-personal information is information that cannot identify you personally, such as, browser information and program data that records the website page choices you have made.

Our website may use 'cookies' to collect non-personal information about you, to help us better deliver our products and services to you. A 'cookie' is a small text file sent to your browser's files for our reference. They allow our server computer to recognize you when you return to our website and retain any preferences you have provided. If you do not wish to receive cookies, consult your browser's help menu to disable the use of cookies.