True Angle Medical Technologies Inc.
Effective upon: May 15, 2020
Last updated: August 11, 2020
True Angle Medical Technologies Inc. (“we” and “us”) is compliant with the Personal Information Protection Act (Alberta), and the Personal Information Protection and Electronic Documents Act (Canada).
Jana Rieger, at firstname.lastname@example.org
We may ask for and collect Personal Information from you. “Personal Information” means information about an identifiable individual, and does not include information that cannot be attributed to an identifiable individual, such as information of an aggregate or anonymous nature.
We will only collect, use, and disclose the Personal Information that we need in order to provide you with the Website and the Services.
Limitation and Withdrawal
We will limit the collection, use, and disclosure of your Personal Information to only that which is necessary for the purposes identified, unless you have otherwise consented, or when it is required by law.
You may withdraw your consent at any time (subject to reasonable notice), unless the Personal Information is necessary for us to fulfill our legal requirements. To withdraw consent, contact our Privacy Officer in writing and advise us of the Personal Information you no longer wish us to use.
You may choose not to provide us with any of your Personal Information; however, if you make this choice, we may not be able to provide you with the Services that you have requested that we provide to you.
The Personal Information we collect and maintain may include:
|· First and last name
||· Mailing address
||· Email address
|· Financial information including credit card information
||· Date of birth
Offline Interactions and Other Sources. We also may collect Personal Information from other sources (such as our partners or third party service providers) or from our offline interactions with you to, among other things, enable us to verify or update information contained in our records and to better customize the Website and the Services for you.
Social Media Integration. Our Website and the Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook or Twitter, and when you do, we may collect additional information from you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We do not have control over the collection, use and sharing practices of social media platforms and encourage you to review their usage and disclosure policies and practices, including the data security practices, before using the social media platforms.
- providing you with information about us, our Mobili-T® device (which is a portable swallowing exercise unit to capture, filter and process physiological signals from muscles used in swallowing, with the capacity to wirelessly connect to electronic mobile monitors, tablet computers, and smart phones), the Website, or the Services;
- the sale and distribution of our Mobili-T® device, including obtaining payment for our Mobili-T® device;
- administering our relationship with you, including creating and managing your Website account;
- facilitating your interactions and transactions with us, including responding to your requests, communications, suggestions, comments, inquiries, and feedback;
- enhancing, modifying, or otherwise improving the Website and the Services for the benefit of our customers, including enhancing the security and/or performance of the Website (and related systems) and the Services;
- developing new services or products;
- measuring performance (e.g. customer service);
- understanding the preferences of our customers, including customer management and analysis;
- the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose;
- responding to legally binding requests from law enforcement, regulatory authorities, or other third parties;
- defending, protecting or enforcing our rights or applicable terms of service;
- preventing fraud or the recurrence of fraud;
- assisting in the event of an emergency; and
- complying with applicable law.
We may use non-personal information for any legitimate business purpose.
The following are particular circumstances in which we may disclose your Personal Information without obtaining your further consent. By disclosing your Personal Information to us, you consent to the following disclosures:
- to our third party service providers, contractors, suppliers, distributors, and partners to help us with the uses described in the Use section above, including to our payment processor if you make a credit card payment;
- to our employees or independent contractors who need access to your Personal Information as part of their job functions to provide you with the Services or to help us with the uses described in the Use section above;
- to insurance companies, banks, and service providers with respect to entering into and fulfilling contracts related to the Website or the Services, or to help us with the uses described in the Use section above;
- to other parties where we are under a duty to disclose your Personal Information in order to comply with any applicable legal obligation including a regulatory process, or an order of a government institution, investigative body, regulatory body or judicial authority of competent jurisdiction;
- to comply with your directions or any additional consent you have provided us;
- where we believe in good faith that disclosure is necessary:
- to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies or investigative bodies in that regard;
- to collect a debt owed to us or to repay any money owed to you;
- to investigate and defend us from and against any third party claims or allegations;
- to protect the security or integrity of the Services; and/or
- to exercise or protect the rights, property or our personal safety, and that of our clients and users, employees, independent contractors, or others;
We disclose non-personal information to third parties as reasonably necessary to meet our business needs. We do not disclose your Personal Information to third parties for their own direct marketing purposes without your consent.
Protection and Retention
We have taken industry standard measures to ensure the security and confidentiality of your Personal Information. We try our best to safeguard Personal Information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your Personal Information, please contact our Privacy Officer as soon as possible.
We will only retain your Personal Information for the period reasonably required to fulfill the purposes for which it was collected. We may retain non-personal information for as long as we have a business need to do so.
All of our service providers and contractors are contractually obligated to employ appropriate data security measures with respect to your Personal Information and to collect/use/disclose/retain it only within the scope required for the provision of the Website and the Services. The contractors we contract with will use your Personal Information if required to perform their respective services. These include, for example, IT service providers that we need to operate and safeguard our IT system that stores your Personal Information.
Access and Updates
On your reasonable written request, we will provide you, not later than thirty (30) days from our receipt of your request, or such additional time as required by law, with access to or information about your Personal Information (if any) under our custody or control, and the names of persons to whom, and any circumstances in which, your Personal Information has been and is being disclosed by us. You must provide sufficient information in your request to allow us to verify your identity and identify the information you are seeking.
We reserve all rights not to disclose Personal Information, in whole or in part, in certain circumstances permitted or required by law, including but not limited to where:
- the disclosure would reveal Personal Information about another individual;
- the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual;
- the Personal Information is protected by any legal privilege;
- the disclosure of the Personal Information would reveal confidential commercial information; or
- the Personal Information was collected by us for an investigation relating to a breach of an agreement or a contravention of the laws of Canada or a province.
If access to your Personal Information is refused, in whole or in part, we will provide you with the reasons for the refusal, the provision of applicable privacy legislation on which the refusal is based, and the contact information of the Privacy Officer who can answer your questions about the refusal, and will inform you that you may ask for a review of the refusal in accordance with applicable privacy legislation.
On your request, we will make every reasonable effort to correct outdated Personal Information, or errors or omissions in your Personal Information where that Personal Information is in our custody or control. Such request must be in writing, signed by the requestor, and include sufficient detail to enable us to identify any record in our custody or control containing the Personal Information in relation to the request. We will, as soon as reasonably possible and not later than thirty (30) days from our receipt of your request, or within such additional time as permitted or required by law, either correct the Personal Information and, if applicable and reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect Personal Information, or decide not to correct the Personal Information, but we will annotate the Personal Information under our control to indicate that a correction was requested but not made. We will inform you of the action that we have taken in response to your request for correction, the contact information of the Privacy Officer who can answer your questions about your request for correction, and that you may ask for a review of the action taken in accordance with applicable privacy legislation.