Ortho Health, Inc. and their affiliates (collectively, “OH”, “we”, “us” or “our”) takes steps intended to meet privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation. The purpose of this statement is to inform our customers and other individuals we deal with (“you’ or “your”) how we collect, use, disclose and protect your personal information both on and off-line. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This statement applies to our collection, use and disclosure of personal information in Canada. This statement does not apply to information about our employees or to information that is not personal information.
1. Personal Information We Collect
- OH and its agents and representatives collect personal information in a number of circumstances in the course of its business. Since the information you submit to us on line may not be encrypted, we cannot guarantee the absolute privacy of that information. Personal information we collect includes:
- Contact information such as name, address, email address and telephone number;
- Information provided when you register or otherwise provide information on our web site;
- Information provided when you complete questionnaires or surveys;
- Information provided when you participate in a promotion or contest;
- Information provided otherwise such as by telephone, by mail or through our web site;
- Records of customer calls or product-related comments or inquiries;
- Such other information we may collect with your consent or as permitted or required by law.
- Contact information such as name, address, email address and telephone number;
2. Use of Personal Information
- OH generally uses personal information for the following purposes:
- Receiving and replying to your requests, inquiries and comments;
- With your consent, sending you information about products and promotions offered by OH and / or contacting you to conduct telephone surveys and market research;
- With your consent, sending coupons from time to time; providing customer service;
- Administering promotions and contests;
- Creating a data base of individuals who have registered to receive information from us;
- Understanding your preferences, needs and interests and, with your consent, offering you products and information that are likely to be of interest to you and personalizing your experience when visiting our web site such as by presenting you with information and offerings that we think will be of interest to you;
- Improving our products;
- Managing our business, including customer relations;
- Ensuring the security of our business operations including our web site;
- Managing, administering, collecting or otherwise enforcing accounts;
- Maintaining business records for reasonable periods and as required by law, and generally managing and administering our business, including defending and prosecuting legal claims;
- Meeting legal, regulatory, insurance, security, accounting and processing requirements;
- Purposes disclosed at the time of collection of personal information;
- And otherwise with consent or as permitted or required by law.
3. Collection of Your Personal Information
- OH collects personal information for the following commercial purposes:
- To establish and maintain responsible commercial relations and to provide ongoing service, and communication;
- To understand customer needs, trends and preferences;
- To evaluate, develop, enhance, market or provide OH products and services;
- To manage and develop OH business and operations;
- To meet legal and regulatory requirements;
- To protect OH against error and fraud;
- And for any other purpose to which an individual consents.
4. Disclosure of Your Personal Information
- OH may disclose personal information, including in the following circumstances to:
- A person who in the reasonable judgment of OH is seeking the information as an agent;
- A company or individual retained by OH to perform functions on its behalf, such as research or data processing;
- A company or individual retained by an individual, who represents that it expressly is entitled to receive such individual’s personal information, or in the reasonable opinion of OH implicitly is entitled to receive such individual’s personal information;
- A company or individual retained by OH for the evaluation, development, enhancement, marketing or provision of any of OH products or services;
- An agent utilized by OH to evaluate the customer’s creditworthiness or to collect the customer’s account;
- A credit reporting agency;
- A public authority or agent of a public authority, if in the reasonable judgement of OH, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information;
- A third party or parties, where the customer consents to such disclosure or disclosure is required by law;
- A financial institution on a confidential basis and solely in connection with the assignment of its right to receive payment, the provision of security or other financing arrangements;
- And professional advisors, consultants, investigators and adjudicators in defending and prosecuting legal claims.
- OH may disclose personal information to affiliates and business partners in order to permit them to send you occasional information about their products and services in accordance with your consent.
- In addition to the above, personal information may be disclosed to our affiliates (outside of Canada including United States of America) for internal audit, management, billing, administrative and other general business purposes.
- Service Providers. OH may transfer personal information to outside agents or service providers (including affiliates of OH acting in this capacity) that perform services on our behalf, for example data processing services such as mailing, call center, billing, marketing, information technology or data hosting or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. Some of these service providers or affiliates may be located outside of Canada, including the USA, and your personal information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for the purposes described in this Privacy Statement. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to legal requirements in Canada, USA and other foreign countries applicable to our affiliates, agents and service providers. For example we may be required to disclose personal information due to lawful requirements to disclose personal information to government authorities in those countries.
- Business Transactions. Personal information may be used by OH and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of OH or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples:
- Permitting those parties to determine whether to proceed or continue with the transaction.
- Fulfilling reporting, inspection or audit requirements or obligations to those parties. Assignees or successors of OH or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Statement.
- Legal, Regulatory, etc. OH may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to OH or our agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).
5. Our Website/The Internet
- Active Information Collection: OH web site actively collects information from its visitors both by asking you specific questions and by permitting you to communicate directly with us via e-mail and/or feedback forms. Some of the information that you submit on the Web site may be personal information. Collection, use and disclosure of information actively collected from you have been described.
- OH web site may use and combine such passively collected anonymous information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the site for your use. Such passively collected anonymous information is not combined with personal information collected elsewhere on the web site, unless you have consented to have your personal information collected in conjunction with this passive information.
6. Your Consent
- Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide personal information necessary for a service you have requested or the purpose is obvious). You may be asked to provide your specific consent in some special and specific circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, you are deemed to consent to our collection, use and disclosure of such personal information for the purposes identified or described in this privacy statement, if applicable, or otherwise at the time of collection.
- You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Note also that where we have provided or are providing products or services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to American and foreign government entities as required to comply with laws, and reporting on credit information after credit has been granted, if applicable).
- OH collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
- About Teenagers and Children: Children under the age of 13: Generally, we do not intend to collect personal information from individuals under the age of 13 without parental consent. We may, from time to time, offer a contest where the child under the age of 13 can enter in which case the personal information is used for purposes of administering the contest and determine a winner. If a child under 13 has provided us with personal information, without parental consent we ask that a parent or guardian of the child contact us to request that this personal information be deleted from our records. We will use reasonable efforts to delete the child’s personal information from our existing files. We encourage parents to talk to their children about their use of the Internet and the personal information they disclose to Web sites or otherwise.
- We will use reasonable efforts to delete all contact and other personal information obtained from a teenager if a parent or guardian notifies us that they wish to withdraw consent for the collection of a teenager’s personal information.
- We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the personal information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and mandataries of OH who require access to your personal information in order to fulfill their job requirements will have access to your personal information.
8. Access, Correction and Contacting Us
- OH may establish and maintain a file of your personal information for the purposes described above, which will be accessible at Ortho Health, Inc., and their affiliates (collectively, “OH”, “we”, “us” or “our”) corporate offices. If you wish to request access or correction of your personal information in our custody or control, or if you wish to make inquiries or complaints or have other concerns about our personal information practices, you may write to the attention of Consumer Affairs through the “contact us” button at the top of this website. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.
9. Links to Other Web Sites
- This web site may contain links or references to web sites to which this Privacy Statement does not apply. OH is not responsible for the data collection and use practices of companies or organizations to which this web site may provide links.
10. Privacy Statement Changes
- This Privacy Statement may be revised from time to time. If we intend to use or disclose Personal Information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us as described above or checking at our website periodically at www.orthohealth.ca to obtain a current copy of this statement. We urge you to request and review this Privacy Statement frequently to obtain the current version. Your continued provision of Personal Information or use of our services following any changes to this Privacy Statement constitutes your acceptance of any such changes. This privacy statement is effective as of July 12th, 2011.