Last Revised: 15 November 2018
This Policy applies only to information we collect, process and use through our websites, including any other website maintained and controlled by us, emails we send, mobile applications or other communication means as identified in this Policy (collectively the “Site”). This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us.
How We Use Information
We collect information about you to provide you with products and services. The data we collect is necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described in this Policy.
Information You Give Us
We collect information when you fill out registration forms, subscribe to newsletters, order products, or provide us with other information actively, we collect that information for processing and use in accordance with this Policy. Depending on how you use our Site, the personal information we collect from you may vary.
The following are some examples of situations in which you will have the opportunity to provide personal information to us:
- you register products online;
- you register/subscribe to receive newsletters,
- you make online purchases;
- you request information or materials through our Site;
- you participate in surveys or contests online;
- you submit questions or comments to us.
Third Party Service Providers
If you use our Site to make an online purchase, your name and address is sent directly to the third-party service provider we use to manage order fulfillment. The service provider is not permitted to use the information you provide except for the sole purpose of order fulfillment on our behalf.
If you enter credit card information on the Site in connection with an online purchase, that information is sent directly to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.
We use a third-party service provider, MailChimp as our marketing automation Site. When you submit information via the MailChimp Site, the information you provide will be transferred to MailChimp for processing in accordance with their privacy terms.
If you connect to the Site using Facebook, Google+, or another networking site (each a “Social Networking Site”), we may receive information that you authorize the Social Networking Site to share with us, which may include your public profile information, birthdate, current city of work, employer, school, and email address. When we receive this information, it becomes part of the information we collect about you and is therefore subject to this Policy. You should note that any information that we collect from your Social Networking Site account will depend on the privacy settings you have set with the Social Networking Site, so please refer to the Social Networking Site’s privacy and data practices. You have the ability to disconnect your Social Networking Site account from Trudell account by changing the privacy settings in your Social Networking Site account. If you arrive at our Site through a Social Networking Site, from other websites or devices that enable third parties to collect information from or about you, such third parties may receive information about you subject to their privacy policies.
Information We Collect Automatically
When you use the Site, your device is automatically providing information to us, so we can respond and customize your Site experience. The type of information we collect by automated means generally includes technical information about computer and/or device, such as your IP address or other device identifier, the type of device you use, and the version of the operating system you are using. The information we collect may also include information and statistics about how you use the Site. That information may include the URL’s of our web pages that you have visited, the URL’s of referring and exiting pages, page views, time spent on a page, number of clicks, Site type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Site.
Automated means of data collection may include the following:
Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Site. For example, when you visit our websites, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.
Device Information. We collect information about the device you use to access the Site, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
How We Share Information
We only disclose your personal information to third parties as follows:
- We use affiliated and unaffiliated service providers all over the world, including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners and others, to help us deliver our products and services. These companies are authorized to use your personal information only as necessary to provide these services to us;
- We may also share your information with Trudell affiliates, namely an entity that directly or indirectly controls, is controlled by, or is under common control with Trudell. Such affiliates shall process your personal information where we believe it is necessary for the purposes of a legitimate interest, and where such purposes are aligned with those for which you provided your personal information to us.
- In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;
- We will otherwise share personal information with your consent.
Other Important Privacy Information
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing materials (such as postal marketing or telemarketing), you may by contacting us using the details provided under the “How to Contact Us” section.
- If we have collected and processed information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. To withdrawal your consent, contact us using the contact details provided under the “How to Contact Us” section.
EEA Resident Rights
In addition to the above rights, if you are a resident of the European Economic Area, and you have the following data protection rights:
- If wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to Contact Us” section.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us using the details provided under the “How to Contact Us” section.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable period of time. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolution of disputes and enforce our agreements.
You may withdraw your consent to the collection, use and disclosure of your personal information at any time, subject to legal and contractual restrictions and reasonable advance written notice.
How Long We Keep Your Personal Information
We keep your personal information only so long as we need it to provide the Site to you and fulfill the purposes described in this Policy. Retention periods can vary based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolution of disputes and enforce our agreements, we’ll remove it from our systems.
Privacy of Minors
To access or use the Site, you must be at least 18 years of age or, the age of majority in your jurisdiction, otherwise you may not use the Site. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a child has provided us with personal information without parental consent, we will remove such information.
Safeguards & Security
We protect personal information we collect with security safeguards appropriate to the sensitivity of the information, including physical, electronic and managerial measures to safeguard the information we collect online; however, we cannot fully eliminate security risks, nor can we make guarantees about any part of products or services. You are responsible for keeping your username and password secret. Once you have created an account with us, we will never ask for your password. Please crease a unique password for your online account and do not share your password with anyone else.
The information about you that we collect, process and use/or use through the Site is controlled by Trudell Medical International, and its affiliates, Trudell Medical UK Limited, TMI Medical Distribution Inc. and some of the services it provides are hosted and provided outside of the European Economic Area (EEA), including Canada and the United States, for the purposes described in this Policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. We take additional measures when information is transferred from the EEA. This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.
How to Contact Us:
By email: privacy [at] trudellmed.com
By mail: 725 Third Street, London, Ontario N5V 5G4
By fax: 519-455-9053
If your questions, concerns, or complaints have not been resolved to your satisfaction, you may contact our Privacy Officer by emailing privacy [at] trudellmed.com.
We may revise this Policy from time to time by posting an updated version on the Site. The revised Policy will be effective immediately. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Site is subject to the most current effective version of this Policy.
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** Ontario registered business name