Accountability, Questions, and Complaints
Personal Information Collected
For the purposes of this Policy, “personal information” means any information about an identifiable individual or any information that can be used, either alone or in combination with other information, to identify an individual, except any information that is exempted by applicable privacy laws.
Directly Collected Personal Information
When you use our Website , we may collect the following personal information directly from you:
Contact information, such as name, email address, mailing address and phone number, if you submit that information to us;
- Activity and usage data, such as performance information and information from your access and use of the Website, including information about the links clicked, searches, features used, items viewed, time spent within the Website, content uploaded or viewed, and other interactions within the Website; and
- Other information you transmit or provide through the Website.
Automatically Collected Personal Information
We, and our third party partners, also automatically collect information about you and any computer or device you use to access the Website. Some of the information we collect, and ways we collect it include:
- Log Files. We may record log file information each time you access the Website. This information may include information such as: your IP address; browser type and language; unique identifiers; information about your computer or device; number of clicks; how you interact with links, features or functionality of the Website; and other such information.
- Usage Data. We also collect information about the way you use our Website, for example, the site from which you came and the site to which you are going when you leave our Website, the pages you visit, the links you click on, how frequently you access the Website, whether you open emails or click the links contained in emails, whether you access the Website from multiple devices, and other actions you take on the Website. We may collect analytics data, or use third party analytics tools, to help us measure traffic and usage trends for the Website and to understand more about the demographics of our users. We may also work with third-party partners to employ technologies, including application of statistical modeling tools, which attempt to recognize you across multiple devices.
Purpose for Which Personal Information is Processed
Generally, SRx Health may process your personal information for the following purposes (the “Purposes”):
- To verify and authenticate your identity;
- To ensure the Website is optimized for your use and benefit;
- To operate, maintain and provide to you the Website and its features and functionality; • To provide you with requested information, process your questions and/or answer your queries;
- To communicate with you to provide its products, services, contacts, materials and/or recommendations for your needs as identified by you through phone, email or the Website;
- To communicate with you to provide you with information about us (including news releases, newsletters and notices regarding upcoming events);
- To solicit feedback from you about your satisfaction and experience with our products and services (including through occasional surveys);
- To comply with internal policies and procedures and other legal, accounting or security requirements; and
- To share your personal information with our employees, contractors, consultants and other third party service providers, such as Internet hosting and technology providers, payment processors, advertising agencies or customer service agencies, as described below.
In all cases, we limit the amount and type of personal information we process to that which is necessary to meet the Purposes for which we intend to process such information. Otherwise, we will not process your personal information without your consent, except where permitted by law.
Transfer and Disclosure of Your Personal Information
We may transfer or disclose your personal information for the Purposes as described above, including as follows:
- To employees, suppliers, service providers and business partners. We may disclose personal information to our employees, contractors, suppliers, service providers, processors and others who perform functions on our behalf. These may include, for example, hosting and technology providers, payment processors, analytics providers, consultants, auditors and legal counsel.
- To affiliates and subsidiaries. We may disclose personal information to our affiliates or subsidiaries, who will use and disclose this personal information in accordance with this Policy.
- To law enforcement, government or regulatory bodies: We may disclose personal information to law enforcement, government or regulatory bodies, or other lawful authorities, including as and when required by law to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our shares or assets are or may be transferred to another company, whether as part of a bankruptcy/insolvency proceeding or otherwise, we may transfer personal information to the other company. We may also share certain personal Information as necessary prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
- Security and protection of rights. We may also disclose personal information to other third parties where we believe doing so is necessary to protect our Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, or (ii) situations involving potential threats to the health, safety or legal rights of any person or third party. We may also disclose information related to litigation and other legal claims or proceedings in which we are involved.
We do not sell your personal information to third parties. Your personal information that we collect may be processed outside of your jurisdiction (including in other jurisdictions in Canada, or outside of Canada) but only in relation to the Purposes and in accordance with applicable laws. As a result, your personal information may be accessible to government, courts, law enforcement and regulatory authorities in accordance with other jurisdictions’ applicable laws.
The Website may contain links to, or advertisements about, third-party websites, applications or Internet resources (“Third-Party Services”), which are provided solely for your convenience and information. When you click on one of those links or advertisements you are contacting those Third Party Services. Third-Party Services may also reference, advertise, or contain links to our Website. We do not endorse or sponsor any such Third-Party Services. We have no responsibility or liability for, or control over, the privacy practices or the content of any Third-Party Services, and we expressly disclaim any representations, statements or assertions made on such Third-Party Services We encourage you to be aware of when you leave our Website and to read the privacy policies of those Third-Party Services to learn how they collect, use and disclose your personal information.
Legal Basis for Processing Your Personal Information
We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested, and may be express or implied.
By using our Website, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected. We will obtain the necessary consents required under applicable privacy laws if we process your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.
If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use the Website or otherwise provide any personal information to us.
You may refuse to provide consent, or notify us at any time that you wish to withdraw or change your consent, to the processing of your personal information, without penalty, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer (at the address above). However, if you withdraw or change your consent, we may not be able to provide you with the Website and you may not be able to use certain features or functionality of the Website.
Other Legal Bases
Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable laws.
Security of Personal Information
We protect personal information using reasonable physical, technological and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.
However, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.
Access and Correction Rights
Applicable privacy laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in their personal information that is on our custody or under our control.
You may request, in writing, access to and review of your personal information under our control. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). However, access may be declined where permitted or required by applicable laws. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
Once we verify your request, we will provide you with your personal information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed.
We make every effort to keep all personal information we hold, including contact information and financial information, accurate, complete, and current. We will update any changes to personal information when received from you through the website. If we hold personal information about an individual which can be established by the individual to be inaccurate, we will take reasonable steps to correct it.
Retention of Personal Information
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retaining the information and retention is no longer necessary for a legal or business purpose.
This Policy was last updated on January 26, 2023. We reserve the right to modify or supplement this Policy at any time; if we do so, we will revise the “last updated” date appearing in this paragraph. If we make a change to this Policy, we will post a notice on the Website or through similar means for a reasonable time after the change(s) take effect. Where required by applicable law, we may need to ask you to confirm your consent to the processing of your personal information. Otherwise, your continued access to or use of our services constitutes your acknowledgment and acceptance of such changes.