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Privacy Policy

 

  1. Protecting Your Privacy. This privacy policy (this “Privacy Policy”) applies to Infotrust Inc. (“Infotrust”, the “company”, “us”, “we” or “our”) and explains how we collect, use, and disclose personal information by way this website (this “Site”) in Canada. Infotrust is committed to protecting your privacy, as it is fundamental to our values and the way we do business. Our management of personal information is governed by applicable law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Health Information Protection Act (PHIPA). In general, “personal information” is information about an identifiable individual, subject to more particular definitions or interpretations under applicable law. This Privacy Policy does not apply to any information that is not personal information as defined in or interpreted under applicable law. Generally, we collect, use, and disclose personal information as necessary to offer and provide clients with certain products and services, including without limitation proprietary home sleep study technical kits (“Infotrust Products and Services”), and otherwise to fulfill our responsibilities with respect to our business.
  2. Changes to This Privacy Policy. This Privacy Statement explains Infotrust’s current practices regarding what information we may collect, use, and secure when you use our services. This statement may vary from time to time with or without any notice. Infotrust reserves the right (in its sole discretion) to change, revise, amend, or modify this Privacy Policy at any time, and we will take reasonable steps to advise affected individuals of any material changes, if required by applicable law. However, you should review this Privacy Policy from time to time to ensure that you are aware of and accept any changes made.
  3. You may contact us to obtain a current copy of this Privacy Policy or if you feel that Infotrust has not handled your personal information in a reasonable manner. Any such requests or any enquiries or complaints regarding this Privacy Policy or Infotrust’s privacy practices should be directed to our privacy officer at:

Infotrust Inc.
Attention: Privacy Officer
snoreclinic@snore.com

In addition, you may contact your provincial Information and Privacy Commissioner.

  1. The Information We Collect. The types of personal information we collect and use will depend upon the information and Infotrust Products and Services requested. However, subject to applicable law, it may include:
    • name, address, email address and other contact details;
    • medical and health related information and data;
    • financial, credit, billing, and account information, insurance information, including public or private health insurance information, and other incidental information relating to the products and services we provide; and
    • any other information we may collect with your consent or as permitted or required by applicable law.
  2. How We Use Information We Collect. We use information we collect:
    • to assess whether we are able to provide you with Infotrust Products and Services;
    • to offer and provide services and deliverables to you, including Infotrust Products and Services;
    • to communicate with you regarding the Infotrust Products and Services or other services you request and to respond to your requests and enquiries;
    • to administer our client databases and issue and collect accounts;
    • to provide you with material on Infotrust Products and Services and other services;
    • to develop and use our knowledge management systems and permit Infotrust personnel to consult documents that we have created on your behalf and that contain personal information;
    • to manage and administer our business; and
    • as permitted or required by applicable law or for purposes for which you otherwise provide your consent.

If you do not wish to receive further materials from us, including regarding Infotrust Products and Services, you may unsubscribe or ask us not to contact you for these purposes.

  1. How We Collect Information. We typically collect personal information directly from you or through our interaction with you. However, we may obtain personal information about you from other sources, including government agencies or third party service providers in connection with Infotrust Products and Services and other services provided to you.
  2. How We Disclose and Share Your Information. We may disclose the personal information we collect about clients or other individuals we deal with to third parties, including:
    • where we are required or authorized by applicable law to do so;
    • where it is necessary to process or collect fees;
    • to regulatory (including self-regulatory) or governmental authorities;
    • where you have instructed us to disclose your personal information to a third party for a designated purpose;
    • where we reasonably believe a third party requesting your information is your agent; and
    • where you consent or as permitted or required by applicable law.
  3. Third Parties. Infotrust may transfer your personal information to our service providers engaged by us to administer or provide products, services or information on our behalf. We use reasonable measures to require the organizations with whom we share your personal information for these purposes to use your personal information only to perform the services we have hired them to provide. Note that some of the service providers that process or handle personal information on our behalf may be located outside of Canada. As a result, your personal information may be transferred, stored and/or processed outside Canada in connection with the purposes described in this Privacy Policy. Contractual or other measures we may use to protect your personal information are subject to the legal requirements of the foreign jurisdictions where your personal information may be transferred, stored or processed, for example, lawful requirements to disclose information to government authorities in those countries.
  4. Our Website. The only personal information that we collect about you when you use this Site is what you tell us about yourself, for example, by completing an online form when you request receipt of Infotrust Products and Services or other services, or information you provide to us through the “Contact Us” section or when you send us an email. You can visit this Site without telling us who you are or revealing any personal information about yourself. Infotrust may collect de-identified data as you browse through the website. As most websites do, we track usage patterns on our website on an anonymous basis. We may use cookies, which is a data file stored on your computer, to collect certain information about you and your use of this Site. This information includes IP addresses, domain names, and the type of computer and operating system being used. We may use cookies to identify your computer when you revisit our website or to track statistical information related to navigation throughout the website. We may also use analytical and audience measurement cookies. These cookies are used for analytical purposes and audience measurement only. The information generated by cookies about your use of this Site is used to evaluate usage trend, which will help us to improve and maintain this Site. You may adjust your browser to refuse to accept cookies, remove cookies, or notify you when a cookie is set by changing your web browser preferences or settings. Please check the “Help” menu on your browser to learn how to change your cookie preferences. You do not have to accept all cookies sent to you by this Site. However, disabling cookies on your web browser may have an adverse effect on some of the features/functions of this Site. The collection and use of such cookies does not allow the identification of individuals and cannot be cross referenced with other processed data. Your identity cannot reasonably be ascertained from this information. Each time you visit our website, our server records your Internet service provider, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URLs you came from. We use this non-personal information to optimize our website service. For your convenience, we may offer links from our website to other websites. However, Infotrust is not responsible for, nor do we accept any liability for, the personal information collection, use, and disclosure practices of other entities to which our website may link. You should consult the privacy policies of these other entities before providing any personal information on their websites.
  5. Your Consent. We collect, use and disclose your personal information with your consent or as permitted or required by applicable law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. For example, in many cases, a client’s consent to the collection, use, and disclosure of personal information by Infotrust may be implied by the fact that the client has engaged Infotrust to provide Infotrust Products and Services or other services, where the collection, use, and disclosure of personal information relates to the performance of those Infotrust Products and Services or other services by Infotrust or third parties or where Infotrust provides Infotrust Products and Services or others services at the request of healthcare professionals. If you provide personal information about another person to us, we assume you have the consent of that individual to enable us to collect, use, or disclose their information as described in this policy. If you choose to provide personal information to Infotrust, we assume that you consent to the collection, use, and disclosure of your personal information as outlined in this Privacy Policy. If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered. Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information or you may withdraw your consent to our further collection, use, and disclosure of information about you, by contacting us via email at snoreclinic@snore.com. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide Infotrust Products and Services, in whole or in part. There are instances where Infotrust may collect, use, or disclose your personal information without your consent, for example, to collect a debt you owe to us, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records.
  6. Infotrust has implemented reasonable physical, organizational, and technological or electronic security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information and reduce the risk of loss or theft or unauthorized access, collection, copying, modification, use, disclosure, and destruction. Authorized Infotrust personnel, agents, and mandatories have access to your personal information. You can generally visit the Infotrust website without providing any personal information. However, given that electronically submitted data is not one hundred percent (100%) secure, we make no warranties as to the security of any such personal information that you submit, which you do at your own risk.
  7. Access and Correction. We maintain a file of your personal information for the above-mentioned purposes. You have the right to access any personal information that Infotrust holds about you. Infotrust will request that you provide sufficient identification information to permit us to account for the existence, use, and disclosure of your information and to authorize access to your file. If you wish to request access to, or correction of, your personal information in custody or control of Infotrust, please make your request in writing to us at the address below. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, or if it is otherwise not properly the subject of an access request. It is important that your personal information be accurate and up to date. Please inform us as soon as possible of any changes to your personal information. If you have any questions, requests or complaints about our personal information practices, please contact us at Infotrust Inc. via email at snoreclinic@snore.com.
  8. Challenging Compliance. You may challenge the accuracy and completeness of the personal information that Infotrust holds about you, and to have it amended as appropriate. All enquiries will be investigated and reported back in a timely manner.