Privacy Policy

(Last updated: January 12, 2024)

Capitalized terms have been defined in Priveo Santé’s Terms of Use. Please read them.

1. Scope and Application

In the face of new challenges and dangers related to the preservation of the security of personal information arising from online business, it is necessary to pay particular attention to the protection of privacy. This is why Priveo Santé is seriously concerned about the privacy of your personal information and is committed to respecting your rights.

Priveo Santé undertakes to comply with, in accordance with this Privacy Policy (” the Policy “) and the laws applicable and in force in Canada and Quebec, the obligations regarding the collection and processing of your personal and confidential information, obtained in the course of the operation of your business, so that everyone can benefit from respect for their privacy.

The Policy applies to you in all situations where you interact with Priveo Santé and where we collect information about you, including when you visit our Website, when you use our services, for example in person at our clinics or when you communicate with us by any means.

In this context, Priveo Santé wishes to ensure the accuracy, security and confidentiality of your personal information, and not to collect, use or disclose your personal information other than in accordance with this Policy and applicable laws.

The Policy describes the information that Priveo Santé may collect from you in the course of its activities, in any way.

The Policy also describes, among other things, how Priveo Santé processes, stores and/or destroys your personal information, the purposes for which it is collected, the use that is made of it and the circumstances in which it may be transmitted to third parties. 

The Policy explains your rights regarding the collection, transfer, use, retention and disclosure of your personal information.

Finally, the Policy describes the ways in which you can access, update or correct your personal information and the choices available to you regarding the protection of your privacy.

You agree that your personal information collected during the completion of any online form in order to, in particular, make contact, upload Content to the Website, or provide other services, may be transmitted to the relevant and authorized personnel of Priveo Santé. The latter will only communicate to third-party companies that carry out activities on our behalf, and whose participation is strictly necessary for the delivery of the Services and/or to maintain our business relationship with you, as the case may be, only the information necessary for these purposes (the above-mentioned third parties may hereinafter be collectively referred to as “the Third-Party Providers“).

In some cases, at the time your personal information is collected, we may provide you with additional information regarding the processing of your personal information. We may also, in some cases, obtain specific consent from you regarding the use or disclosure of your personal information. For example, Priveo Santé may ask you to complete a consent form for your personal information to be transferred to a Third-Party Provider, for example when you want us to share it with your insurer or employer.

By browsing the Website, accepting this Policy, or providing us with personal information after you have had the opportunity to review this Policy or any additional notice, you agree that your personal information will be treated in accordance with the Policy and the additional notice. 

By providing Priveo Santé with your personal information, you authorize it to use and communicate it to Third Party Providers, if applicable, in the context of the delivery of services, the management of our contractual relationship, our commercial relationship with you, and this in accordance with this Policy and as authorized or required by law, as well as implicitly, if indicated by the circumstances.

In addition, Priveo Santé will seek your authorization before using your personal information for purposes other than those covered by your initial consent given under the Policy.

We collect only the personal information reasonably required to provide and manage our services and activities. We collect your personal information in a variety of ways. For example, we collect it directly from you, from Third Party Providers, or when you visit our Website.

Finally, you may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please be aware, however, that without your consent, Priveo Santé may no longer be able to provide you or may continue to provide you with some of the services or information that may be useful to you.

If you provide Priveo Santé or its Third-Party Providers with personal information about another natural or legal person, you agree that you have the necessary authorization to do so and/or that you have obtained all necessary consents from that third party to allow us to collect, use and disclose their personal information for the purposes set out in this Policy.

2. Our Privacy Officer 

Please do not hesitate to contact our Privacy Officer with any questions or comments you may have regarding the Policy, how we handle your personal information, or to exercise your rights regarding your personal information. 

You can reach our Privacy  Officer: 

Priveo Santé Clinic

Éric Latendresse – Privacy Officer,

1435 Saint-Martin Blvd. West, Suite 425,

Laval, Quebec H7S 2C6

Email: [email protected]

3. Roles and responsibilities of Priveo Santé staff

Within Priveo Santé, we have assigned roles and responsibilities as follows:

The Privacy Officer is responsible for: 

1. the implementation of confidentiality policies and procedures within Priveo Santé;

2. training our staff on privacy  policies and obligations;

3. maintain a record of incidents related to the confidentiality of personal  information;

4. assess the potential consequences of a privacy  incident;

5. notify the Commission d’accès à l’information in the event of a confidentiality incident involving personal information that could cause serious  harm; and

6. Participate in identifying the risk of confidentiality breaches and notify responsible persons in the event of a confidentiality incident.

The Director of Operations is responsible for :

1. ensure that all of our employees have signed the confidentiality agreement and that it is recorded on the server ;

2. ensure control of employees’ access rights to the server ;

3. ensure that all Third Party Providers have and comply with a privacy policy for personal  information; and

4. Participate in identifying the risk of breach of confidentiality and notifying responsible persons in the event of a confidentiality incident.

Administrative staff are responsible for : 

1. collect customers ‘ personal information;

2. obtain consent to the use of personal information and scan it into the patient’s  chart;

3. sign and abide by the confidentiality  agreement; and

4. Participate in identifying the risk of confidentiality breaches and notify responsible persons in the event of a confidentiality incident.

Clinical staff are responsible for : 

1. comply with the Privacy  Policy;

2. Assist in identifying the risk of privacy breaches and notifying those responsible in the event of a privacy-related  incident;

3. uphold their ethical standards.

Priveo Santé trains and raises awareness among its staff members and its Professionals (” Employees “) by: 

1. explaining the clauses of the confidentiality contract when it is signed at the time of hiring and by reminding you of it on an annual basis thereafter ;

2. periodically reminding employees of confidentiality requirements at annual employee  meetings; or

3. raising awareness of the reporting of privacy incidents.

4. Definition of Personal Information

Personal information is information specifically associated with a natural person and can be used to identify that person, either as such or by combining it with other information held by Priveo Santé or to which he or she may have access. Information that has been anonymized or that has been arranged so that it can no longer be used to identify a specific individual is not personal information. For example, the mailing address of an individual’s office is not personal information in itself, except when it is mentioned with other information about the individual, or when the mere mention of it would reveal personal information about the individual.

5. What personal information do we  collect?

We collect the following  personal information: 

1. Information about your identity and contact information, such as your first and last name, date of birth, residential address, telephone number, email address, gender, height and weight, health  insurance number;

2. Health-related information , such as your medical record, in whole or in part, a medical certificate with or without a diagnosis, answers to medical questionnaires given, the fact that you consulted a doctor or other health professional, the date of the consultation or teleconsultation, your list of medications, prescriptions issued, medical results, email or chat attachments sent by the customer,  the type of appointment made, insurance  data;

3. Information about the specific services you have purchased from Priveo Santé, including on the Website, such as your appointment history, and the time and date of your past and future appointments, requests for Quotes made ;

4. Your payment information, such as the time and date of payment, the amount paid, the type of card used, the full name on the card, and your credit card number, if you make a purchase on the Website ;

5. Employee  identity information: first and last name, date of birth, address, salary, telephone number and social insurance number;

6. Bank account details for Employees ; 

7. Information collected automatically when you visit our Website, such as visit or chat history, time and date, or cookies have been accepted, and preferences chosen.

6. How do we collect your personal  information?

We collect your personal information in the following  ways: 

1. by telephone ;

2. by making an appointment on the Website ;

3. in person at the clinic ;

4. by email or chat app;

5. contact form or submission available on the Website;

6. by subscribing to the newsletter on the Website ; 

7. via clinic  forms; and

8. via the employment contract and the employee record for Employees. 

7. From whom do we collect your personal  information?

We generally collect personal information in the following ways:

1. Directly from you or the holder of parental authority if you are a minor or your tutor or mandatary, if applicable

You may provide personal information to us directly, such as in person at the clinic, through a teleconsultation, by mail, email, telephone, fax or through the Website, such as by booking an appointment or chatting with us. 

You can provide us with your personal information by filling out your employment contract and your employee file, for Priveo Santé employees. 

Like what:

1. When you come to a point of service to have examinations, analyses or require treatment, we collect your personal information necessary to provide these services and to communicate the results, if applicable. We also collect your health information from tests or examinations.

2. When you participate in a teleconsultation session with a Professional, we collect the personal information necessary to provide you with the required health care and services. The use of a telemedicine platform is subject to the privacy policy of the provider of the Website in question. When you contact us by phone to make an appointment, we collect the personal information necessary to complete the appointment scheduling.

3. We may record calls to our Customer Relations Center for quality control purposes. In this case, we will notify you at the beginning of the call and you will not be asked for any sensitive personal information.

4. We collect personal information related to a medical prescription when you submit it to us electronically or in person. 

5. When you use a chat service on the Website to chat with a Priveo Santé representative (in this case, you must at all times comply with the instructions communicated via the chat service interface and in our Terms of Use, regarding the nature of the information you are authorized to share and you must avoid providing personal information where prohibited).

2. Through other sources

From time to time, we may receive personal information from other sources. In these cases, we only receive it with your consent or if required by law where permitted.

Like what:

1. If you are required to undergo a pre-employment medical examination, your employer may provide us with information about you.

3. Via the Website

Through cookies or pixel tags (” Cookies“)“), we collect certain information from exchanges between your computer and our server. Cookies are files created by a website that record information about your computer’s navigation on the site. They are automatically stored on your electronic devices, allow you to connect to the Website for future use and allow Priveo Santé to personalise the Website. 

This mainly includes the following information: 

1. Domain name;

2. IP address;

3. Language of the User; and

4. Browsing history.

Most cookies do not allow us to identify you. It is only collected due to technological requirements inherent in Internet browsing. Most browsers automatically accept cookies, but it is usually possible to change this behavior. However, if you choose to refuse Cookies, you may not be able to log in or use certain features of the Website.

The use of such information allows us to improve the service, personalize your experience, and better track your past usage. 

In addition to the methods described above, we may also collect information through the use of Cookies or similar technologies, such as during your visits to our Website. These methods allow us to collect various types of information, including the pages you visit, the emails you read, and other information.

Like what:

1. We may use your location to determine in which language to display the Website when you visit the Website.

2. Subject to applicable laws, we may use the pages visited on the Website to provide you with personalized advertisements on the External Sites of our Third Party Partners.

We use the information collected in this way to tailor the Website to your preferences, to compile statistics about your consultation and use of our Website and our electronic communications, such as our newsletters, in order to improve them, and to present you with Priveo Santé advertisements with the help of our partners.

The Cookies we use include, but are not limited to, the following:

1. Cookies, which are small text files that are stored on your computer when you visit a website, so that certain information can be saved between your visits, such as your access data or your choice of language. For example, cookies allow you to log in quickly when you visit our sites.

2. pixels, which are small image files containing information about you, such as your IP address, that can be downloaded when you visit a website or open an email. This allows us to understand your online behavior, monitor the delivery of our emails, and provide you with personalized advertisements. These tools also allow our third-party tracking tools to collect information, such as your IP address, and transmit it to us as anonymized aggregated data (thus preventing us from identifying you). The personal information compiled and presented as aggregated data is synthesized and does not include any personal identifiers.

We use Google Analytics and Plerdy, which are services that use cookies to analyse your use of our Website, to produce reports for us on the activities of visitors to the Website and to offer other services related to the use of the Website and the Internet. This information is not provided to us in a form that identifies you.

There are many Cookies, some of which expire when the User closes their browser and no longer have any effect, while others can be retained. The User may disable Cookies at any time. In this eventuality, Priveo Santé does not guarantee an optimal functioning of the Website.

8. How do we use Cookies?

We use technologies such as cookies or pixels that perform different functions on our Websites. More information on the use of these technologies can be found in the Cookie Policy.

This information is also used to :

1. Understand how you use the Service without tracking you specifically ;

2. Keep a record of the services you are interested in and obtain information about you from current or future divisions or companies that are part of Priveo Santé ;

3. To process your requests and respond to your questions;

4. To stay in touch with you and provide you with a personalized service at all times;

5. Communicate with you (by email, mail, or otherwise) and send you advertising materials or additional information about the Services;

6. Develop new products and services; and

7. Conduct market and performance research to evaluate client service, measure performance, enhance user experience and improve services.

9. Why do we collect your personal information?

We use your personal information to provide our services to you, to manage our business, to provide you with offers and information that we believe will be of interest to you, to enhance your overall customer experience, and for other purposes permitted or required by law.

Specifically, we use your personal information for the following purposes:

1. To provide you with our services

We use your personal information to provide you with our services and, more specifically, for the following purposes:

1. Verify your identity ;

2. To provide our services to our patients and clients ;

3. Allow you to book an appointment online or in person ;

4. Determine whether our products and services are appropriate for you ;

5. Administer your file, including your online portal, to better meet your needs ; and

6. Respond to your requests and questions. 

I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO  ALLOW PRIVEO SANTÉ TO PROVIDE ITS MEDICAL CLINIC SERVICE

2. To manage our operations

We use your personal information for a number of reasons in the course of our business and operations, specifically to:

1. To manage the Website and facilitate its use.

2. To allow you to participate in surveys or, where applicable, promotions, chats, seminars or workshops.

3. Monitor and investigate incidents. 

4. To comply with our legal and regulatory obligations. 

I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO  ENABLE PRIVEO SANTÉ TO MANAGE ITS OPERATIONS

3. To allow us to communicate with you

We use your personal information to communicate with you in a variety of ways:

1. Send you our newsletter.

2. Inform you in various ways (e.g., by email, phone, text or direct mail) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you.

3. To provide you with personalized advertisements about our products or services, if we believe they may be of interest to you.

If you no longer wish to receive our commercial e-mail messages, please follow the unsubscribe procedure in each such message.

I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO  ALLOW PRIVEO SANTÉ TO CONTACT ME

10. What happens if you do not consent to the collection of your personal  information?

You may, at any time, opt out of the collection of your personal information. 

Please note, however, that, with the exception of Cookies, which are not necessary for the provision of services, we will not be able to provide the services offered at the clinic without having access to your personal information. 

For an Employee, we will not be able to establish the employment relationship, including by entering into an employment contract, without having access to your personal information.

11. Who, outside of Priveo Santé, might have access to your personal information and how do we share this information?

Priveo Santé staff and Professionals, and, with your written or oral consent and where necessary, our Third-Party Providers, may have access to your personal information. 

We may disclose your personal information to our Third Party Providers and other third parties – with your consent or where otherwise permitted by law – for the purposes described in this Policy and in accordance with applicable law (for example, under the An Act respecting the sharing of certain Québec health information). We do not sell your personal information unless we sell or transfer a portion of our business.

We do not share your personal information with individuals or legal entities outside of Priveo Santé, except as set out below:

1. Third-party service providers whose intervention is necessary to provide you with the service

We may share personal information with our Third Party Providers. These Third Party Providers help us provide our services, operate our business, operate our technology systems and applications and infrastructure, and implement our internal procedures and advertising and marketing strategy. They provide us with, for example, data hosting, email deployment, marketing, sales, and processing or analysis of personal information. We may also outsource certain services we provide to our customers to third parties, including laboratories and healthcare professionals.

Like what:

1. In order to serve our customers, we may use third-party laboratories to perform certain tests and analyses.

2. Our patient records are hosted with an electronic medical record (EMR) provider.

3. We may use an email provider to send you our newsletter.

4. We may use a service provider’s chat website to provide you with a service that allows you to interact directly with a Priveo Santé representative.

5. We may use a provider for data storage and/or sending and receiving email.

6. We may use a service provider’s Telemedicine Website to provide you with teleconsultations with a healthcare professional.

7. We may use online payment platforms offered by third parties in order to process payment for benefits.

By using Priveo Santé’s services, you consent to your personal information being processed through the systems of providers that allow us to interact with various electronic medical records (EMRs).

2. The purchaser of Priveo Santé if Priveo Santé is sold or transferred or in certain other corporate transactions

We may decide to sell or transfer all or part of our business or to a third party, merge with another entity, insure our assets, or engage in any other financing or strategic transaction involving the capital of our business (including insolvency or bankruptcy proceedings), a restructuring, share sale or other change in control of Priveo Santé. You consent to the disclosure of your personal information when required for the purposes of such a transaction.

3. Other third parties when required or permitted by certain laws

The law permits or requires the collection, use or disclosure of personal information without consent in specific circumstances (for example, to investigate suspected or actual illegal activities, to prevent such activities, including fraud, or to assist government and law enforcement agencies). These circumstances include those where permitted or required by law and where it is necessary to do so to protect ourselves, our Employees, customers or others. In such circumstances, we disclose only the personal information that is reasonably necessary to fulfill the purposes for which we are disclosed.

Please note that under applicable Quebec and Canadian laws (e.g., Quebec’s Public Health Act and the Quarantine Act) Emergency Orders issued under these Acts, and Ministerial Orders, Priveo Santé may be required to disclose your personal information to authorized persons, including but not limited to the Institut national de santé publique du Québec (INSPQ) and the Public Health Agency of Canada (PHAC), as well as their authorized representatives and agents.

We may disclose personal information we hold for the purpose of protecting an individual or group of individuals when there are reasonable grounds to believe that there is a serious risk of death or serious bodily harm, including a disappearance or an act of violence, including a suicide attempt, that person or group and that the nature of the threat inspires a sense of urgency. The information may then be shared with the person(s) exposed to the risk, their representative, or any person who may be able to assist them. Only the information necessary for the purposes of the communication will be disclosed.

We may also communicate information to the Director of Criminal and Penal Prosecutions or to a person or group responsible for preventing, detecting or suppressing crime or offences under the law when the information is necessary for the purposes of prosecuting an offence under a law applicable in Québec. 

Finally, we may share information with a police force when it is necessary to plan or execute an intervention adapted to the characteristics of a person or the situation, in any of the following cases: 

(i) the police force intervenes, at our request, to provide us with assistance or support in the course of the services we provide to a person; 

(ii) we act in consultation or partnership with the police force in the context of mixed psychosocial and police intervention practices. 

4. Other third parties, with your consent

In addition to the above-mentioned purposes, we may, with your express or implied consent and in compliance with applicable law, communicate or disclose your personal information with persons or entities outside of Priveo Santé.

Like what:

1. With your consent or at your explicit request, we may share your information with your insurer, employer, etc.

12. How long do we keep your personal  information?

We store your personal information at our offices, with our archive and on our computer servers. Except where the law provides for a different retention period, we retain personal information only as long as necessary to fulfill the purposes for which it was collected. The duration may therefore vary depending on the nature of the information.

13. What are the risks associated with the processing of your personal  information? 

Given the risks inherent in the use of computer systems, however, we cannot ensure or warrant the security or confidentiality of any information you transmit or provide to us, and you do so at your own risk. If you have reason to believe that personal information has been compromised, please contact us using the contact information set out in section 2 of the Policy. If a password is used to protect the User’s account and personal information, it is the User’s responsibility to keep it confidential. 

Priveo Santé is committed not only to keeping a record of confidentiality incidents, but also to implementing internal practices to limit or prevent the consequences of a confidentiality incident involving personal information.

A privacy incident can be : 

1. unauthorized access to personal information by law; 

2. unauthorized use of personal information; 

3. disclosure of personal information that is not authorized by law; or  

4. loss of personal information or any other breach of the protection of such information.  

In the event of a confidentiality incident involving your personal information held by Priveo Santé, Priveo Santé will notify you and the Commission d’accès à l’information du Québec of any confidentiality incident that poses a risk of serious harm.

14. Is your personal information transferred outside of Quebec?  

Some of your personal information may be transferred outside of Quebec. In this case, the servers of the Third Party Providers whose intervention is necessary for the provision of services are located in other Canadian provinces or territories, the United States, the Netherlands and Germany. 

Prior to any transfer of your personal information outside Québec, Priveo Santé conducts a privacy impact assessment, specific to the proposed transfer. Priveo Santé thus ensures that the protection measures put in place demonstrate an adequacy of the protection conferred on the personal information transferred. 

15. How can you change your choices about the protection of your personal information?

You can always withdraw your consent for your personal information to be used for purposes other than those that are absolutely necessary for the provision of our services, without this having any consequences on the services you receive from Priveo Santé.

For example: You can always opt out of receiving communications of an advertising nature from Priveo Santé.

You have different options to make your choices:

1. Indicate your choices at the time of registration or by contacting us directly at any time

You can always indicate your choice not to receive marketing messages from Priveo Santé by email by clicking on “unsubscribe” in any email you receive.

Please note that even if you have indicated your opt-out of receiving marketing messages from us, we may still contact you in connection with a service in accordance with applicable law (e.g., provide you with a customer service message). In addition, it could take up to 10 business days for a preference change to be recorded in all of our records.

b. Change your device’s browser settings

We use technologies to improve your customer experience and present you with offers, including personalized advertising. By means of technologies such as Cookies, for example, our Website recognises you when you use or return to it, and can thus provide you with a continuous experience. You can delete or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features of our Websites.

16. How do we protect and store your personal information?
    
    

The security of your information is important to us and we are committed to protecting your privacy through a range of administrative, physical and technical safeguards. We retain your personal information for as long as necessary to provide our services to you, to manage our business, and to comply with our legal and regulatory obligations.

The personal information that Priveo Santé collects is kept in a secure environment. Priveo Santé has adopted appropriate measures to preserve the confidentiality of personal information and to protect it against loss or theft, as well as unauthorized access, communication, reproduction, use or modification, taking into account, in particular, its sensitivity and the purposes for which it is used. In addition, Priveo Santé requires that each Employee, agent or representative of Priveo Santé comply with this Policy.

has. Protective measures put in place

To protect your personal information, we employ administrative, technical and physical safeguards. Our goal is to prevent unauthorized access, loss, misuse, disclosure or alteration of personal information in our possession. We ensure that access to your personal information is at all times restricted to only those employees and agents of Priveo Santé who are justified by law to have access to it. We also use these safeguards when we dispose of or destroy your personal information.

b. Where We Store Your Personal Information

We use all reasonable security measures, which may include imposing contractual obligations on our service providers, to protect your personal information wherever it is used or stored.

Unless we are legally required or contractually required to keep your personal information in Canada, it may be transferred outside of Canada as set out in Section 13. For example, some of our service providers may access, process or store your personal information outside of your province or territory or Canada for the purposes of the services they provide to us. In this case, the personal information is governed by the laws of the jurisdiction in which it is used or stored, including any law authorizing or requiring disclosure of the information to government authorities or agencies, courts and law enforcement authorities in that jurisdiction. Priveo Santé ensures that its Third-Party Providers are located in jurisdictions that provide a level of protection for personal information in accordance with the laws applicable in Quebec. 

c. How long we keep your personal information

We retain your personal information for as long as necessary to provide our services to you, to manage our business, and to comply with our legal and regulatory obligations (for example, health care providers must comply with legal retention obligations with respect to patient records). When we no longer need it, we will securely destroy your personal information or anonymize it (so that it can no longer be used to identify you).

d.Destruction of Your Personal Information

Personal information is destroyed in accordance with the rules set out in the regulations enacted by the Collège des médecins du Québec, by the laws applicable in Québec with respect to the management of human resources and by the laws applicable in Québec for the protection of personal information.

17. What are your rights with respect to personal  information? 

You have a number of legal rights in relation to your personal information. To exercise any of these rights, please contact our Privacy Officer using the contact information provided in section 2 of this Policy. 

Access: the right to ask if we hold personal information about you and, if so, to request access to that personal information. To the best of our ability, we will provide access to information in a timely manner. However, as a security measure, we may need to verify the identity of the applicant. 

Rectification: the right to request rectification of any incomplete or inaccurate personal information we hold. 

Withdrawal of Consent: The right to withdraw your consent to the disclosure or use of personal information held, subject to applicable legal and contractual restrictions. It is possible that Priveo Santé will no longer be able to provide you with certain services if you withdraw your consent. 

Restricting or denying access: the right to request that a particular stakeholder or a member of a specified class of stakeholders not have access to one or more pieces of information that you have identified.  

Complaint: the right to make a complaint to our Privacy Officer as identified in Section 1 in connection with this policy and the complaints handling procedure. If you are not satisfied with the way we have handled your personal information or if you believe that a breach of privacy laws has occurred, you may file a complaint with the Commission de l’accès à l’information du Québec. To file a complaint with the Commission, please use the appropriate form available on the Commission d’accès à l’information du Québec website.

Portability: You have the right to request that your personal information be disclosed to you or transferred to another organization in a structured and commonly used technological format.

18. How do you access your personal information?

You have a right of access to the personal information we hold about you, subject to any restrictions provided by law. Upon request, we will provide you with access to your personal information within thirty (30) days of receipt of your request. Access to personal information is free of charge, but a reasonable fee may be charged for the transcription, reproduction or transmission of such information.

It is your responsibility to provide accurate, truthful and complete information. If you notice any errors in your personal information or need to update it, please notify us as indicated below.

You may make a request by contacting us using the contact information for the Privacy Officer at the beginning of the Policy.

19. How do I know if the Privacy Policy has changed?
    
    

We may make changes to this Policy from time to time. Any changes we make will be effective when we post the amended Policy on this web page. If we make material changes to the policy, we will post a notice on our Website or contact you to let you know, where required by law. By continuing to use our services following the posting of the amended version of the Policy, you indicate that you accept the changes to the Policy, subject to any additional requirements that may apply. If you do not agree to the changes to our Policy, you must stop using our services. It is your responsibility to ensure that you read, understand and agree to the latest version of the Policy. The “Effective Date” at the top of this Policy is the date this Policy was last updated.

20. Who can I contact if I have questions about the protection of your personal information?

If you have any questions about how we handle your personal information, please contact the Privacy Officer whose contact information is in section 2 of this Policy.