External Privacy

At Tassone Health Innovations Inc. (“THI”), we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that THI collects from or about you, how we use and to whom we disclose that information.

 

THI has adopted a series of Privacy Policies in order to address the specific privacy concerns of certain groupings of individuals. This Privacy Policy applies to the personal information of all individuals.

 

Privacy Policy Effective for Canada

 

It is THI’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

 

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

 

What Is Personal Information?

 

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.

 

What Personal Information Do We Collect?

 

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

 

  • contact and identification information, such as your name, address, telephone number and email address;

 

  • product-and-service related information concerning the products and services that we provide to, or receive from, you, such as processing your order, corresponding with you or providing you with a subscription;

 

  • credit and financial information, such as your direct deposit and banking and credit card information;

 

  • business relationship information, including information related to your agreements, preferences, advisors and decision-makers, as well as any feedback and information requested by or provided to you; and

 

  • market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning.

 

As a general rule, THI collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such source (such permission may be given directly by you, or implied from your actions).

 

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

 

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

 

Why Do We Collect, Use and Disclose Personal Information?

 

THI collects personal information to enable us to manage, maintain and develop our business and operations, including:

 

  • to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested (for example, we will use your personal information to establish your identity and location so that we may provide you with the products and services that you have requested);

 

  • to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;

 

  • your use of our Web site and subscriptions through the use of various technologies. For example, when you visit our Web site or access our subscription, we may log certain information that your browser sends us, such as your IP address, browser type and language, access time, and referring Web site addresses, and we may collect information about the pages you view within our sites and other actions you take while visiting us. In addition, some of our software products include technologies that allow THI to collect certain information about product use. We may also use such technologies to determine whether you’ve opened an e-mail or clicked on a link contained in an e-mail. Collecting information in this manner allows us to collect statistics about the usage and effectiveness of our Web site, our software products and subscriptions, personalize your experience and tailor our interactions with you;

 

  • to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;

 

  • to comply with your requests (for example, if you prefer to be contacted at a business or mobile telephone number and advise us of your preference, we will use this information to contact you at that number);

 

  • to protect us against error, fraud, theft and damage to our goods and property;

 

  • to enable us to undertake our environmental, health and safety activities, including incident planning, response and investigation; and

 

  • any other reasonable purpose to which you consent.

How Do We Use and Disclose Your Personal Information?

 

We may use or disclose your personal information:

 

  • if you request something from THI, for example, a product or service, a callback, or specific marketing materials, we will use the information you provide to fulfill your request. To help us do this, we may share information with others, for instance, THI’s business partners, financial institutions, shipping companies, or postal or government authorities, such as Customs authorities, involved in fulfillment. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes;

 

  • to provide you with a personalized experience on our Web site, such as providing you with content in which you may be interested and making navigation on our sites easier;

 

  • to support products or services you have obtained from us, such as notifying you of a product update or fix;

 

  • in the course of providing technical support to you, we may sometimes have incidental access to data that you have provided to us or data that is located on your system. This data may contain information about you, your organization’s employees, customers, partners, or suppliers. This Privacy Policy does not apply to our access to or handling of this information; the conditions regarding the handling and processing of that data is covered by the applicable THI Inc. Master Subscription Agreement for URU Program or other agreements between you and THI;

 

  • for marketing purposes. Before we do so, however, we will offer you the opportunity to choose whether or not to have your information used in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by indicating so when we call you, or by contacting us directly;

 

  • Certain online transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is THI’s general practice to monitor and in some cases record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction; or

 

  • for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

 

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

 

When Do We Disclose Your Personal Information?

 

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist THI in the provision of services to you; and third parties whose services we use to conduct our business.

 

In addition, personal information may be disclosed or transferred to another party during the course of or completion of, a change in ownership of or the grant of a security interest in, all or a part of THI through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and is required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

 

Further, your personal information may be disclosed:

 

  • as permitted or required by applicable law or regulatory requirements;

 

  • to comply with valid legal processes such as search warrants, subpoenas or court orders;

 

  • as part of THI’s regular reporting activities;

 

  • to protect the rights and property of THI;

 

  • during emergency situations or where necessary to protect the safety of a person or group of persons;

 

  • where the personal information is publicly available; or

 

  • where required by law, with your consent.

 

Information Security and Accuracy

 

We intend to protect your personal information and to maintain its accuracy. THI implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt certain sensitive personal information such as credit card information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure.

 

Retention

 

We will retain your registration information for as long as your account is active or as needed to provide you services. If you wish to request that we no longer use your registration information to provide you services contact us at [email protected]. We will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Cookies, Web Beacons and Other Technologies

 

As mentioned above, we collect information from your visits to our Web site and your use of our subscription and our software products to help us gather statistics about usage and effectiveness, personalize your experience, and tailor our interactions with you. We do so through the use of various technologies, including one called “cookies”. A cookie is a piece of data that a Web site can send to your browser, which may then be stored on your computer as a tag that identifies your computer. While cookies are often only used to measure Web site usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to personalize a known visitor’s experience to a Web site by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.

 

Cookies are typically categorized as “session” cookies or “persistent” cookies. Session cookies help you navigate through the Web site efficiently, keeping track of your progression from page to page so that you are not asked for information you have already provided during the current visit. Session cookies are stored in temporary memory and erased when the web browser is closed. Persistent cookies, on the other hand, store user preferences for current and successive visits. They are written on your device’s hard disk, and are still valid when you restart your browser. We use persistent cookies, for example, to record your choice of language and country location.

 

Most browsers, by default, automatically permit cookies, but also give you the ability to control the majority of cookies, including whether or not to accept them and how to remove them. Look under the heading “Tools” (or similar heading) in your particular browser for information about controlling cookies. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it or not. You can also generally set your browser to turn off cookies. Cookies in our software products can be turned off in the product itself. Since cookies allow you to take advantage of some of our Web site’ features or features of our software products and subscription, we recommend that you leave them turned on. If you block, turn off or otherwise reject our cookies, some Web pages may not display properly or you will not be able, for instance, to add items to your shopping cart, proceed to checkout, or use any Web site services that require you to sign in. Some THI Web site, subscription and software products may also use Web beacon or other technologies to better tailor those sites to provide better customer service. These technologies may be in use on a number of pages across THI’s Web site. When a visitor accesses these pages, a non-identifiable notice of that visit is generated which may be processed by us or by our suppliers. These Web beacons usually work in conjunction with cookies. If you don’t want your cookie information to be associated with your visits to these pages or use of these products, you can set your browser to turn off cookies or turn off cookies in the product itself, respectively. If you turn off cookies, Web beacon and other technologies will still detect visits to these pages; however, they will not be associated with information otherwise stored in cookies.

 

For more information about the technologies employed by our subscription and software products, including how to turn them off, please consult the documentation related to your subscription. We may also include Web beacons in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links contained within clicked on.

 

Your Consent Is Important to Us

 

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be express, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

 

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.

 

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

 

Deemed Consent (Opt-Out)

 

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

 

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

 

How Is Your Personal Information Protected?

 

THI endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

 

Updating Your Personal Information

 

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

 

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

 

Access to Your Personal Information

 

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing. Generally, your information is kept at our corporate offices in Ontario.

 

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

 

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

 

In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

 

 

Inquiries or Concerns?

 

If you have any questions about this Privacy Policy or have any concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by email. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

 

Privacy Officer

 

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

 

By mail:           THI Privacy Officer

1120 Finch Ave. West

Suite 701

Toronto, Ontario

M3J 3H7

By telephone:   416-650-0734

By e-mail:        [email protected]

 

 

Revisions to this Privacy Policy

 

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website uruhealth.com and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on November 27, 2017.

 

Interpretation of this Privacy Policy

 

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.

 

This Privacy Policy does not create or confer upon any individual any rights, or impose upon THI any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.