- how we collect, use and disclose Personal Information;
- the choices you have regarding the use and disclosure of Personal Information; and
- How you may correct Personal Information.
The following topics will be covered in this Privacy Statement:
What is Personal Information and what Personal Information do we collect?
How and when do we collect Personal Information?
Where do we store Personal Information?
For what purposes do we collect your Personal Information?
What safeguards have we implemented to protect the Personal Information that you provide?
Who will have access to the Personal Information that you provide?
To whom do we disclose Personal Information that you provide?
When and how do we obtain your consent?
How long will we use, disclose or retain Personal Information that you provide to us?
How can you review your Personal Information that we have collected, used or disclosed?
How do you know that the Personal Information we have on you is accurate? What happens if such Personal Information is inaccurate?
How do you contact us regarding access to your Personal Information or our privacy practices?
1. What is Personal Information and what Personal Information do we collect?
“Personal Information” is any information that about an identifiable individual. The type of Personal Information that we may collect may include, for example:
- contact information, such as email address and residential address;
- phone numbers;
- credit card information and bank account information (i.e. where provided to us in the course of paying membership dues);
- social media identifiers (e.g. Twitter handle and Facebook profile, etc.);
- internet protocol (IP) address; and
- other information that falls within the definition of “Personal Information” that we did not request, but that you provide to us.
Personal Information does not include business contact information (such as information regarding where an individual practices their profession and/or the contact information for that practice) and certain publicly available information.
2. How and when do we collect Personal Information?
We will always collect Personal Information by fair and lawful means. We may collect Personal Information from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent to do so, or as otherwise required or permitted by law.
Generally, however, we collect Personal Information directly from you when you voluntarily provide it in the course of using the Services. For example, Personal Information may be collected when:
- you request an appointment through the Website;
- you submit a question through the Website;
- you register to receive our newsletter or any other THS publications; and
- you communicate with representatives of THS, via telephone, email or mail.
3. Where do we store Personal Information?
We store Personal Information that you provide on our servers (or those of our service providers) in Canada.
4. For what purposes do we collect your Personal Information?
Generally, we identify the purposes for which we use the Personal Information that you provide at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use Personal Information for the following purposes (the “Purposes”):
- Typically your information is only stored at your request, through an appointment, or through signing up for our newsletter.
- Your information is not collected or stored merely by visiting our website or social media pages.
5. What safeguards have we implemented to protect the Personal Information that you provide?
We have implemented physical, organizational, contractual and technological security measures in an effort to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. For example, we have implemented the following safeguards:
- premises security;
- security software and firewalls to protect hacking or other unauthorized computer access; and
- password protected and encrypted computers.
The safeguards we implement to protect your Personal Information reflect industry standards. For example, if you provide credit card information to us, such information is: (i) encrypted (using socket layer (SSL)); and (ii) stored in Cliniko which is password protected and encrypted.
Moreover, as noted below, we will only permit our employees and third party service providers to access your Personal Information on a “need-to-know” basis and only after they have entered into an agreement under which they are bound to comply with applicable legislation (including privacy legislation), this Policy and related policy and procedures.
We take reasonable steps to verify your identity before granting you access to your account on the Website. However, you are solely responsible for maintaining the secrecy of your username, password and any other account information. Users should not disclose their username or password.
6. Who will have access to the Personal Information that you provide?
7. To whom do we disclose Personal Information that you provide?
We will only disclose your Personal Information where we are required by applicable law to do so. We identify to whom, and for what purposes, we may disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. For example, we may disclose your Personal Information to:
- A signed request by a lawyer or MVA company
- a signed warrant issued by a court in the applicable jurisdiction
In the event that we are required by applicable law to disclose your Personal Information without your consent, we will aim to disclose only the specific information that is required in the circumstances and, if possible, inform you about the disclosure.
8. When and how do we obtain your consent to collect, use and disclose Personal Information?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing any Personal Information you provide to us for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances. You may provide your consent to us either orally, electronically or in writing.
We also require users who are submitting Personal Information to the Website that is about another individual, to only do so if they have the consent of that individual (or their substitute decision-maker, if applicable).
(a) Cookies – Generally
The Website also uses “cookies” to help personalize and maximize your online experience. Cookies are text-only pieces of data that a website transfers to your hard drive or other website-browsing equipment for record-keeping purposes. Cookies often include unique, non-personal identifiers and permit the Website to recognize you and to keep track of your preferences. Three types of cookies may be employed during your visit to the Website:
- third-party cookies: these are installed by third parties (including Google and Facebook, as described below in paragraphs (b) and (c) of this Section 9) with the aim of collecting certain information to carry out various research into behaviour, demographics, etc. An example of such a cookie is Facebook like button or sharing on social media options;
- “session” cookies, which are not permanently stored on your hard drive and are permanently deleted from your computer after two hours of inactivity or when you end your session (i.e. leave the Website), and are used solely to help you to navigate the Website; and
- “persistent” cookies, which remain on your computer so that the Website can recognize you when you return. Persistent cookies will remain on your computer after you have left our Website and will expire when you log out of the Website, or 60 days after your last visit for security cookies.
Cookies are also used for the following reasons:
- When you watch a video clip or listen to an audio clip on through the Website, a cookie may take note of which media player (such as Real Player or Windows Media Player) and which type of clip (high or low bandwidth) you prefer to use on your computer. Note, however, that you can change your video and audio preferences at any time or choose a player each time you view or listen to a clip.
Cookies are not used to run programs or to deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you.
Please note that while most browsers are initially set to accept cookies, you have the ability to disable cookies if you wish, generally through changing your internet browser settings. It may also be possible to change your browser settings to enable acceptance of specific cookies. For more information on enabling and disabling cookies, please refer to the help section on your browser. Disabling cookies may cause some of the Services or functions of the Website to become unavailable or inaccessible.
(b) Google Analytics
The Website uses web analysis services provided by Google Inc. (“Google”), specifically, “Google Analytics” and “Google Tag Manager”. Among other things, Google Analytics tracks traffic to, from and within the Website and provides CCA with information regarding use of the Website. Information collected by Google, including cookies and usage data, is processed in the United States of America and may be subject to the laws of that jurisdiction (including the federal Patriot Act).
Google Analytics may:
- set or read cookies on browsers of users of the Website; and
- otherwise receive information from users’ browsers.
However, prior to being stored on Google’s servers, your IP address is anonymized.
For more information on Google Analytics, please visit:
- For further information regarding how Google uses information from sites or applications that use Google’s services: www.google.com/policies/privacy/partners/
- To opt out of Google Analytics data collection and/or to obtain instructions on removing Google Analytics from your browser: https://tools.google.com/dlpage/gaoptout
(c) Facebook Pixel
The Website also uses Facebook Pixel to better understand the actions taken by users of the Website and to offer such users products and/or services in line with their interests, by providing measurement services and targeted ads. For more information on Facebook Pixel, please visit:
- For a copy of Facebook’s Data Policy: https://www.facebook.com/about/privacy/
- For further information on cookies and other storage technologies used by Facebook, including information on how to opt-out of same: https://www.facebook.com/policies/cookies/
10. How long will we use, disclose or retain Personal Information that you provide to us?
We will use, disclose or retain Personal Information that you provide to us for as long as necessary to fulfill the Purpose(s) for which that Personal Information was collected, and as permitted or required by applicable law.
11. How can you review your Personal Information that we have collected, used or disclosed?
If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by applicable law. We will attempt to make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
12. How do you know that the Personal Information we have on you is accurate? What happens if such Personal Information is inaccurate?
We will attempt to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you to supply us with updates to your Personal Information, as required, using the functionality of the Website (or by other means, where appropriate).
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
13. How do you contact us regarding access to your Personal Information or our privacy practices?
By mail: Privacy Officer- Town Health Solutions
96 Stanley Street
Saint John, NB
By telephone: 506-652-5222
14. Other Information