Blog Archive
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Blog Archive
- ► 2023 (8)
- ► 2022 (88)
- ► 2021 (54)
Comments Needed to the FDA
October 2016
The Food and Drug Administration (FDA) is finally taking some major steps to tighten scrutiny of the labeling (and accompanying advertising) messages that the infant formula industry has been using to market their products in the US. Please consider sending a strong message to FDA to keep it up -- and do more! Please consider submitting a comment letter by the November 8 deadline, using the templates provided. Also, please spread the word to your networks, so that we can counter expected industry push-back by generating as many letters as we can in the next few weeks. These are due by November 8, 2016.
The United States Breastfeeding Coalition describes the effort to call industry manufacturers to task, and have the Federal Drug Administration increase their surveillance and enforcement of claims made by the industry. This link will take you to the USBC blog, which provides details:
http://www.usbreastfeeding.org/p/bl/et/blogid=63&blogaid=1021
On September 9, FDA, for the first time ever, proposed draft guidance for industry, entitled "Substantiation for Structure/Function Claims Made in Infant Formula Labels and Labeling,” which describes the type and quality of evidence that the FDA thinks industry should use to substantiate structure/function claims, recommends that the evidence meet "competent and reliable evidence” standards, and strongly suggests that companies use clinical research trials to back up their assertions.
It has been reported that the US pet food industry is currently better regulated than the AIM industry! I love my pets, but I personally and professionally think this is so dangerous. The industry producing AIM should not be allowed to continue the largest uncontrolled experiment on our infant population. Make them answerable to the FDA and to their own claims that their products are "more like mother's milk" or "now containing Human Milk Ogliosaccarides" along with all other misleading comments meant to indicate their competitor's product is inferior.
Step 2 Education International Inc.
Montreal, Quebec, Canada
H4A 1G2
Courriel
This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from https://step2education.com (the "Site").
PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as Device Information."
We collect Device Information using the following technologies:
- "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- "Web beacons," "tags," and "pixels" are electronic files used to record information about how you browse the Site.
Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as "Order Information."
- Users who are undertaking a course as part of a group or organization have certain data tracked as part of the service we provide to Clients and Facilitators. This includes information showing if you have logged in and when, dates of completion and what and when particular study topics, resources and assessments were viewed and completed. We refer to this information as "Student Access Information"
When we talk about "Personal Information" in this Privacy Policy, we are talking about Device Information, Order Information and Student Access Information.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use Student Access Information to provide accurate tracking to Users and Clients on completion and use of the courses, as well as for analysis on how to improve our services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, with your employer who needs to verify your completion or progress of your studies. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
BEHAVIOURAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative's ("NAI") educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info.
DO NOT TRACK
Please note that we do not alter our Site's data collection and use practices when we see a Do Not Track signal from your browser.
YOUR RIGHTS
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
DATA RETENTION
When you place an order through the Site, we will maintain your Order Information and Student Access Information for our records unless and until you ask us to delete this information. We are required to keep course completion records for at least 5 years in order to comply with certain accreditation requirements.
CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:
5890 Monkland Avenue, #16, Montreal, QC, H4A 1G2, Canada
Last Updated: September 2018