Privacy Policy

True Angle Medical Technologies Inc.
USA Privacy Policy

Effective upon: July 20, 2020
Last updated: July 6, 2020

At True Angle Medical Technologies Inc.  (“True Angle”, “us”, “our”, or “we”), we are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, disclose and protect your personal information, as well as how you can manage the personal information we collect from you. This Privacy Policy applies to your use of our website https://www.trueanglemedical.com/ and all of its associated services, including product delivery and collection of payment (collectively, the “Services”).

By using our Services, you are accepting the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Services. If you do not understand, or if you have questions about, this Privacy Policy, please contact us before using, or continuing to use, our Services.

The date on which the Privacy Policy was last amended is indicated above. We reserve the right to change our Privacy Policy from time to time. We will post notice that the Privacy Policy has been amended on the first webpage of our website for a period of thirty (30) days. The amended Privacy Policy is effective when posted. Your use of our Services after we have made changes to our Privacy Policy will mean that you have accepted those changes.

Nothing contained in this Privacy Policy is intended to create a contract or agreement between us and you.

If you have questions or concerns regarding this Privacy Policy, please contact our Privacy Officer:

Jana Rieger, at jana.rieger@trueanglemedical.com

Collection

We collect two basic types of information from you when you provide it to us or when you use or interact with our Services: personal information and non-personal information.

Personal information includes all information that relates to you personally and either identifies or may be used to identify you personally (collectively, “personal information”). We may collect various types of Personal Information from you depending upon how you interact with us or use or interact with our Services, such as your:

  • Contact Information. First and last name, date of birth, email address, postal address, and other contact information.
  • Purchase information: Financial information including credit card information.

Non-personal information includes information that does not personally identify you (i.e. aggregated information) or information that has been anonymized (collectively, “non-personal information”). When we combine non-personal information with personal information, we treat the combined information as personal information.

You can always refuse to provide us with your information, except that it may prevent you from using our Services or receiving responses to your inquiries or other information of interest.

Cookies. Our website may use cookies, which are small text files that are stored on your device by the browser when you visit certain webpages that record your preferences and actions. We use cookies to monitor traffic, improve our website and make it user-friendly. Like many websites, we use cookies, web beacons and similar technologies to record your preferences and track the use of our Services. We use these technologies to:

  • Remind us who you are when you access our Services which helps us to provide you with services tailored to your specific needs and interests;
  • Determine the browser you are using so our Services work properly;
  • Assist us with sending you notifications;
  • Generate analytics regarding your use of our Services; and
  • Estimate our audience size by determining whether your visit is your first.

You can set your browser or device to refuse all cookies or to indicate a cookie is being sent. Some cookies remain stored on your device until you delete them. If you delete your cookies or if you set your browser or device to decline these technologies, some Services may not function properly. Our website does not currently change the way it operates upon detection of Do Not Track or similar signal.

Online Analytics. We also use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Services. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Services, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

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 Services for you.

Social Media Integration. Our 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.

Surveys and Promotions. From time to time, we may provide you with the opportunity to participate in surveys or other promotions, some of which might be sponsored or conducted by a third party. Participation in these surveys and promotions is completely voluntary. If you choose to participate, we will request certain personal information from you. If there is a third party sponsor involved in the survey or promotion, please make sure to review the sponsor’s privacy policy. Please be aware that any sweepstakes, raffles, surveys or similar promotions offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Policy. By participating in any such sweepstakes, raffles, surveys or similar promotion, you will become subject to those rules, including but not limited to receiving emails containing promotion communications.

How We Use Information

We may use personal information to:

  • provide 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;
  • facilitate your interactions and transactions with us;
  • respond to your requests, communications, suggestions, comments, inquiries, and requests (including your feedback about our Services);
  • administer our relationship with you, including creating and managing your account;
  • enhance, modify, or otherwise improve our Services;
  • measure performance;
  • develop new services or products;
  • sell and distribute our Mobili-T® device including obtaining payment for our Mobili-T® device;
  • better understand the preferences of our customers, including customer management and analysis;
  • provide personalized Services, including content and ads;
  • provide you with, and improve, relevant marketing offers or information from us or relevant third parties;
  • enhance the security and/or performance of the Website (and related systems) and the Services;
  • use it for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose;
  • respond to legally binding requests from law enforcement, regulatory authorities, or other third parties;
  • defend, protect, or enforce our rights or applicable terms of service;
  • prevent fraud or the recurrence of fraud;
  • assist in the event of an emergency; and
  • comply with applicable law.

We may also combine your personal information collected through various sources, including information collected through our Services, and develop of a customer profile that will be used for the purposes above.

We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose.

How We Disclose Information

Except as disclosed in this Privacy Policy, we do not share personal information with any third parties other than our partners and affiliates and their directors, officers, employees, agents, consultants, advisors, or other representatives. In no event will we sell or rent personal information.

The following are particular circumstances in which we may disclose personal information:

  • to our third party service providers, contractors, suppliers, distributors, and partners to help us with the uses described in the How We Use Information section above;
  • to our payment processor, if you make a credit card payment;
  • to our employees or contractors who need access to your Personal Information as part of their job functions to provide you with our Services or to help us with the uses described in the How We Use Information section above;
  • to insurance companies, banks, and service providers with respect to entering into and fulfilling contracts related to our Services, or to help us with the uses described in the How We Use Information section above;
  • to law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:
    • responding to a subpoena, court order or other legal processes;
    • defending, protecting or enforcing our rights;
    • assisting in the event of an emergency; and
    • complying with applicable law.
  • 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;
  • to comply with your directions or any additional consent you have provided us;
  • as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation; and
  • if we are involved in asserting or defending a legal claim, we may disclose information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

We share non-personal information with third parties as reasonably necessary to meet our business needs.

Protecting and Retaining Information

We have taken industry standard measures to ensure the security and confidentiality of personal information. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. 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 information, please contact us immediately.

We may retain personal information for as long as we have a legal requirement or business need to do so, including, for backup, archival, accounting, and/or audit purposes. We may retain non-personal information for as long as we have a business need to do so.

Children’s Privacy

Our Services are not for children under the age of 13. We do not knowingly collect personal information from children under 13 years of age. Individuals under the age of 13 should only use our Services with the permission and under the supervision of a parent or guardian. Individuals under the age of 13 should not attempt to provide us with any personal information. If you think we have received personal information from children under the age of 13, please contact us immediately.

Your California Privacy Rights

We do not share personal information with third parties for their own direct marketing purposes without your consent. If you are a California resident under 18 years old, in certain circumstances, you may request and obtain removal of personal information or content about you that you have posted on our Services. Please be mindful that this would not ensure complete removal of the content posted on our Services by you. To make any request pursuant to California privacy law, please contact us.

Your Choices

We offer you certain choices in connection with our Services:

Updating your information. The accuracy of the information we have about you is very important. You may request that we update your personal information by contacting our Privacy Officer.

Email communications. You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your e-mail address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

Cookies. If you wish to minimize information collected by cookie or beacon, you can adjust the settings of your device or browser. You can also set your device or browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some Services may not work properly. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Do Not Track. Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Our website does not currently change the way it operates upon detection of Do Not Track or similar signal. Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

Third Party Websites and Apps

The Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

Contact Us

We welcome questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have questions, concerns, or feedback, you can always contact our Privacy Officer below. For your protection, we may need to verify your identity before assisting with your request.

Jana Rieger, at jana.rieger@trueanglemedical.com

 

 

 

True Angle Medical Technologies Inc.
Canadian Privacy Policy

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).

This Privacy Policy applies to your use of our website https://www.trueanglemedical.com/ (the “Website”), and all of its associated services, including product delivery and collection of payment (collectively, the “Services”).

By using the Website, you are accepting the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website. If you do not understand, or if you have questions about, this Privacy Policy, please contact us before using, or continuing to use, the Website.

The date on which the Privacy Policy was last amended is indicated above. We reserve the right to change our Privacy Policy from time to time. We will post notice that the Privacy Policy has been amended on the first webpage of the Website for a period of thirty (30) days. The amended Privacy Policy is effective when posted. Your use of the Website after we have made changes to our Privacy Policy will mean that you have accepted those changes.

Nothing contained in this Privacy Policy is intended to create a contract or agreement between us and you.

If you have questions or concerns regarding this Privacy Policy, please contact our Privacy Officer:

Jana Rieger, at jana.rieger@trueanglemedical.com

Purpose

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.

Consent

We will only collect, use, disclose, and store your Personal Information after obtaining your consent, except where otherwise permitted or required by law. We will obtain your express consent prior to or when collecting, using, or disclosing your Personal Information for any purpose not described in this Privacy Policy, or for a purpose that was not identified to you nor reasonably expected at the time of collection, unless we are required by law not to obtain your consent.

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.

Collection

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

Cookies. The Website may use cookies. These are small text files that are stored on your device by the browser. We use cookies to make the Website user-friendly. Some cookies remain stored on your device until you delete them and make it easier for us to recognise your browser when you next visit us. If this is against your preference, you can set your browser so that it informs you when cookies are set and only allows this in individual cases. However, deactivating cookies may limit the functionality of the Website.

Online Analytics. We also use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use our Website and the Services, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

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.

Surveys and Promotions. From time to time, we may provide you with the opportunity to participate in surveys or other promotions, some of which might be sponsored or conducted by a third party. Participation in these surveys and promotions is completely voluntary. If you choose to participate, we will request certain Personal Information from you. If there is a third party sponsor involved in the survey or promotion, please make sure to review the sponsor’s privacy policy. Please be aware that any sweepstakes, raffles, surveys or similar promotions offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Policy. By participating in any such sweepstakes, raffles, surveys or similar promotion, you will become subject to those rules, including but not limited to receiving emails containing promotion communications.

Use

We will only use and disclose your Personal Information to fulfill the purposes for which it was collected and in accordance with this Privacy Policy, unless otherwise consented by you in advance, or as may be permitted or required by law. We use Personal Information for certain legitimate business purposes, which include:

  • 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.

Disclosure

Except as set forth in this Privacy Policy, or as required or permitted by law, we do not disclose your Personal Information to any parties other than our service providers and our affiliates, and their respective directors, officers, employees, agents, consultants, advisors or other representatives who or that have a need to use your Personal Information to provide (or improve) our Services, to legal or regulatory authorities, or for other purposes for which you have provided your consent. In no event will we sell or rent your Personal Information.

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;
  • where we transfer or are considering transferring control of any or all of our assets, operations or services to a third party acquirer of all or substantially all of our assets, including our rights and obligations relating to our services, to a third party. The third party may continue to retain and use the Personal Information that you provided to us. We will act in a reasonable manner, including by contractual or other means, to ensure that the third party agrees to similarly be bound by this Privacy Policy or a privacy policy that provides substantially similar measures to those employed by us to protect the privacy and security of your Personal Information and to similarly comply with applicable privacy legislation with respect to your Personal Information, but we cannot guarantee such latter compliance by the third party acquirer; and
  • where we merge or amalgamate with a third party, the amalgamated entity may continue to use and disclose your Personal Information. We will attempt to ensure that the amalgamated entity agrees to similarly be bound by this Privacy Policy or a privacy policy that provides substantially similar measures to those employed by us to protect the privacy of your Personal Information and to similarly comply with applicable privacy legislation with respect to your Personal Information, but we cannot guarantee the amalgamated entity’s compliance.

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.

Contractors

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.

If you request a copy of your Personal Information and the Personal Information can reasonably be reproduced, we will provide you with a copy of the record or the part of the record containing the requested Personal Information or, if applicable, we will give you reasons for any delay in providing a copy of the requested Personal Information or record. If the requested record cannot reasonably be reproduced, we will permit you to examine or access the record or part of the record in accordance with this Privacy Policy.   All requests may be subject to minimal costs.

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.