Privacy & Ethics Policy

Last Updated June 28, 2018

Diversified Communications ULC and its products and services (the “Company”) maintains and supports various web Pages which provide you with information and links related to Company’s Services (“Pages” and “Company Services” are defined more specifically in Company’s Services Terms of Use Agreement) as well as to some services and products of third parties. This Privacy and Ethics Policy (“Privacy Policy”) sets forth Company’s policy with respect to any information, including personally identifiable data (“Personal Data”) that is collected from individuals like you who access Pages and from individuals who register for and/or use the Company’s Services whether through a subscription, and online activity or live education event.

What Information Does Company Collect?

1. Personal Data That You Provide Through Pages: Company collects Personal Data from you when you voluntarily choose to provide such information, such as when you contact Company with inquiries, register for or utilize Company’s Services. Whenever Company collects Personal Data, Company makes an effort to provide a link to this Privacy Policy or, where the Personal Data is collected in person, via mail or via the telephone, Company notifies you where it can be located. Company may rely upon third party service providers to collect and process your registration for Company’s Services. These service providers are only permitted to use your Personal Data as specified herein. By voluntarily providing Company with Personal Data, you are consenting to Company’s use of it in accordance with this Privacy Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Company and the authorized third parties referred to herein for the purposes described in this Privacy Policy. Personal Data does not include information you provide that is also publicly available through professional licensure programs or otherwise, even if it relates to you personally.
2. Other Information:

(i)    Non-Identifiable Data: When you interact with Company through Pages, Company may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Company may store such information itself or it may be included in databases owned and maintained by Company affiliates, agents, or service providers. Company may use such information and pool it with other information to track, for example, the total number of visitors to Pages, the number of visitors to individual Pages, and the domain names of Company visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

(ii)    Cookies: In operating Pages, Company may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts Pages gives to your browser when you access a Website. Company cookies help provide additional functionality to Pages and help Company analyze the usage of Pages more accurately. For instance, Pages may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the site. In cases in which Company uses cookies, Company will not use such cookies to collect Personal Data unless such collection has been disclosed to you in advance. Please see the section entitled “Personal Data That You Provide Through Pages” above for information about the Personal Data that Company collects. On most Web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Company recommends that you leave cookies turned on because they make your use of their site much easier and provide you access to all of Pages’ features.

(iii)    Google Analytics, Google Adwords and other third party applications.  Pages may have implemented Google Analytics, Google Adwords and other third party applications for Display Advertising, in order to advertise online via its “Remarketing” feature. Third-party vendors, including Google, may show our ads on sites across the Internet.  We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to Pages. You can opt-out of the Google Analytics Advertiser Features we use, including through Ads Settings, Ad Settings for mobile apps, or any other available means through this link. To opt out of Google Adwords advertising features, click here.

(iv)    Aggregated Personal Data: In an ongoing effort to better understand and serve the users of Company Services, Company often conducts research on Company customer demographics, interests, and behavior based on the Personal Data and other information provided to Company. This research may be compiled and analyzed on an aggregate basis, and Company may share this aggregated data with Company affiliates, agents, and business partners. Company may also disclose aggregated user statistics in order to describe Company’s Services to current and prospective business partners and to other third parties for other lawful purposes. When Company shares this information in aggregate form, it does not identify you personally.

(v)   Photography and video: In operating its live events, Pri-Med may take photos and videos of conference attendees and faculty. These photos and videos may be used in Pri-Med marketing materials and on Pages. Should you wish for a photo of you which is identifiable, not to be used for any purpose you must advise Pri-Med in writing as directed below at section 11.

How Does Company Use Your Personal Data and Other Information?

Company uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, Company may use the Personal Data in connection with the reason for which it was obtained. For instance, if you contact Company by e-mail, Company may use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Company’s Services, Company will use your Personal Data to provide access to such services.

If you register for and/or use the Company’s Services, Company will use your Personal Data to provide you with documents and other materials related to such Company’s Services, and Company may also mail you documents and materials related to such Company’s Services as well as for other products, and services and that Company believes will be of interest to you.

Company and Company affiliates may also use your Personal Data and other personally non-identifiable information collected through Pages to help Company improve the content and functionality of Pages, to better understand Company’s users, and to improve or market the Company’s Services. Company and Company’s affiliates may use this information to contact you in the future to tell you about services or products Company believes will be of interest to you. If Company does so, each communication Company sends you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or to have your name deleted from Company mailing lists please contact Company as indicated below. Company may also share your Personal Data with certain third parties as described further in the section labeled “Does Company Share Your Personal Data?”

If Company intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected, and given the option to opt-out of such use.

Does Company Share Your Personal Data?

Company considers your information to be a vital part of the relationship with you and protects it vigorously. There are, however, certain circumstances in which Company may share your Personal Data with certain third parties without further notice to you, as set forth below:

A. Business Transfers: As Company develops Company business; Company might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be part of the transferred assets.

B. Related Companies: Company may also share your Personal Data with Company subsidiaries and affiliates for purposes consistent with this Privacy Policy.

C. Event Sponsors: If you sign-up to attend an event or participate in an activity as a part of Company’s Services, Company may share your registration information with non-related companies that are involved in supporting the applicable event, including, without limitation, technology companies.

D. Business Partners: From time to time, Company may offer you the opportunity to participate in discount plans and similar benefit programs from one or more of Company business partners. If you opt-in to participate in the discount plans or other benefit programs of Company business partners, Company will disclose your Personal Information to such business partners so that they may register you for the applicable discount plan and/or benefit program.

E. Agents, Consultants, and Related Third Parties: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, print and online advertising, and processing payments. When Company employs another company to perform a function of this nature, Company endeavors to provide them only with the information that they need to perform their specific function and Company instructs them to limit their use of the Personal Data accordingly.

F. Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of Pages or the public, or (iv) protect against legal liability.

G. By having an exhibitor or sponsor scan your badge at an event, checking into a virtual booth or participating in a virtual passport program, you are opting in to share your full contact and demographic information with that exhibitor. Your contact information would then fall under that exhibitor or sponsor’s privacy policy which you may request from them.

Exclusions

This Privacy Policy shall not apply to any unsolicited information you provide to Company through Pages or through any other means. This includes, but is not limited to, information posted to any public areas of Pages, such as a community forum like the Company’s user board, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All such Unsolicited Information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, and/or distribute such Unsolicited Information to others without limitation or attribution.

Children

Company does not knowingly collect Personal Data from children under the age of 18. If you are under the age of 18, please do not submit any Personal Data through Pages. Company encourages parents and legal guardians to monitor their children’s Internet usage and to help enforce Company Privacy Policy by instructing their children to never provide Personal Data on Pages without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to Company through Pages, please contact Company and Company will endeavor to delete that information from Company databases.

Links to Other Web Sites

Pages may frame or contain references or links to other websites not operated or controlled by Company, including websites of Company Related Companies and unrelated companies with which Company has a business relationship (the “Third Party Sites”). The policies and procedures Company describes here do not apply to the Third Party Sites. The links from Pages do not imply Company reviewed or endorses the Third Party Sites. Company suggests contacting those sites directly for information on their privacy policies.

Advertising & Marketing

Company may target our advertising and marketing messages depending on preferences you choose to share with us. Pages may personalize content based on your interests. For example, you may see different content on our site in different areas based on information that you have shared with us or based on observations we have made regarding your previous usage.

We require advertisers and their advertisements to comply with all Federal (Canada) and local regulations regarding direct-to-physician advertising. We reserve the right to reject any advertisement for any reason.

Security

Company takes reasonable steps to protect the Personal Data provided via Pages from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from Pages may not be secure. Therefore, you should take special care in deciding what information you send to Company via e-mail.

Other Terms and Conditions

Your access to and use of Pages is subject to the Services Terms of Use Agreement.

Changes to Privacy Policy

Pages and Company business may change from time to time. Additionally, laws, rules & regulations affecting customer privacy also change over time.  As a result, Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of Pages after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Company

If you would like to confirm the accuracy of your Personal Data or request a personally identifiable photo of you not be used, please contact Company as specified below. Company will take reasonable steps to fulfill your request.

Also feel free to contact Company if you have any questions about Company Privacy’ Policy or the information practices included on Pages.

You may contact us as follows:

Attn: General Manager

 Diversified Communications ULC

1101 Kingston Rd., Suite 310 | Pickering, ON, L1V 1B5

info@pri-med.ca | info@accountex.ca