1. Toronto Naturopathic Clinic’s commitment to Privacy
· why we collect personal information and personal health information;
· what we do with that information;
· what steps we take to ensure that the information is secure;
· who you should contact if you have questions or concerns about our policies or practices.
Children: We do not intend to collect information from children who are under 18 years of age. If you are under 18, please do not provide information on our Sites and you are not eligible for membership.
2. What is personal information?
In general terms, personal information means any information about an identifiable individual. For example, this includes your name, postal and email address, telephone number, credit card number, demographic information and purchasing history. A special category of personal information is “personal health information,” which we describe below.
Personal information does not include aggregate information, such as data about a group or category of products, services or customers, from which individual customer identities have been removed. For example, information about how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data. Likewise, information about the products you purchase may be collected and combined with information about the products purchased by others.
We may also gather aggregate information about how Toronto Naturopathic Clinic customers use our Sites. Aggregate information about product purchases helps us understand trends and customer needs, and assists us in product selection, product ordering and sizing, and the introduction of new products and services.
3. What is personal health information?
Personal health information means any information relating to your physical or mental health collected or generated in the course of our providing you with the health services you request, Examples of personal health information may include your medical history, drug prescription information, or health insurance information, which we may require in order to provide you with certain services. It may also include information you provide to Toronto Naturopathic Clinic health services personnel when receiving counselling or advice, or when contacting Toronto Naturopathic Clinic with a comment, question or complaint about our health services.
4. When we collect personal information
We only collect such personal information as is strictly necessary for us to provide you with services you request. We collect personal information when you:
· apply for membership
· renew your membership;
· contact us with questions, inquiries, comments, complaints or requests;
· sign up for certain products or services offered under Toronto Naturopathic Clinic Care
· use our Sites;
· participate in any of our programs;
· place orders, make purchases, return or exchange items, or seek further information about our products and services;
· enter into a contest or sweepstakes or respond to one of our surveys; and
· ask us to place you on a “Do Not Email” list so that we can ensure that your wishes are respected.
· Interact with us on Social media
Please note that Toronto Naturopathic Clinic Services may be provided by unaffiliated third parties and their affiliates, agents and subcontractors (“Service Providers”). These Service Providers may collect and provide us with personal information in connection with the Toronto Naturopathic Clinic Services, such as a list of our customers who have signed up for Toronto Naturopathic Clinic Services and information about the use our customers make of such Toronto Naturopathic Clinic Services (for example, frequency of use and customer feedback).
5. How we use personal information
As part of our business operations, we hold and use certain personal information pertaining to you in order to process your requests, provide you with Toronto Naturopathic Clinic Services, and to understand your needs so that we can serve you better.
Specifically, we may use personal information for the following purposes:
· Notifying you of recalls or safety issues;
· Approving you as a member when you apply for membership;
· Managing the provision of goods, services and privileges to you, including monitoring your membership, processing exchanges or returns, to conduct a credit check if you choose to pay by cheque, to determine your credit status and for fraud detection and identification purposes;
· Managing invoicing, accounting and information security services related to our transactions with you;
· Monitoring your satisfaction with our programs, including the services offered by our suppliers of Toronto Naturopathic Clinic Services and contacting you regarding the status of such programs and services (for example, to inform you of changes to or the termination of particular Toronto Naturopathic Clinic Services);
· Internal management purposes, including planning, resource allocation, policy development, quality improvement, monitoring, audit, evaluation and reporting;
· Managing our “Do Not Email” lists; and
· Using personal information to create aggregate information as described above
If you ask us to, we will also tell you about news, promotions, special offers and other information from Toronto Naturopathic Clinic, regarding Toronto Naturopathic Clinic, Toronto Naturopathic Clinic Affiliates and selected partners, such as our promotional programs. You may unsubscribe from these kinds of messages at any time by visiting Toronto Naturopathic Clinic.com and setting your Communication Preferences.
6. When we share personal information
From time to time we engage Service Providers to perform various services. For example, a Service Provider may be asked to perform credit card processing services, manage claims, deliver certain products or services, administer a contest, deal with customer inquiries, or help us better serve you, including by notifying you of special programs regarding products or services that may be of interest to you. We also may use a Service Provider to host and administer one or more of our Sites, process and store data, and fulfill administrative, marketing or technology-related functions on our behalf. In these circumstances, the personal information that the Service Provider receives is limited to only the personal information held by us that they need in order to render their service to us. Service Providers have their own policies and processes in place to ensure that the confidentiality of information in their care is properly safeguarded at all times.
You acknowledge that if Toronto Naturopathic Clinic Affiliates or Service Providers provide services from other countries, your personal information may be processed and stored in these countries and the governments, courts or law enforcement or regulatory agencies of these jurisdictions may be able to obtain disclosure of your personal information in accordance with their laws.
We may disclose personal information without your knowledge or consent if a law, regulation, search warrant, subpoena or court order legally authorizes us or requires us to do so. We may also disclose personal information to protect the rights, property or personal safety of Toronto Naturopathic Clinic, its customers, employees or other members of the public.
Except as set out above, we do not sell, rent, share or disclose the personal information or personal health information we hold or make our membership list available to others for a fee without your consent.
7. When we collect, how we use and when we share personal health information
In the course of providing you with Toronto Naturopathic Clinic Care services and or related services and programs we introduce from time to time, we collect, use and disclose personal health information. Toronto Naturopathic Clinic, Toronto Naturopathic Clinic Affiliates and their Service Providers may collect, use or disclose your personal health information in connection with:
· providing you with the health services you request;
· communicating with your health service providers;
· storing electronic health records within onsite or offsite servers;
· processing or obtaining payment for government-funded health services (for example, obtaining authorization from your insurer or provincial authorities for direct payment of pharmacy services);
· processing or obtaining payment from your health insurance provider;
· internal management purposes, including planning, resource allocation, policy development, quality improvement, monitoring, audit, evaluation and reporting;
· providing Toronto Naturopathic Clinic with technological or administrative services
· the sale, assignment or other transfer of our business
We may also disclose personal health information without your knowledge or consent if a law, regulation, search warrant, subpoena or court order legally authorizes us or requires us to do so or to protect the rights, property or personal safety of Toronto Naturopathic Clinic, its customers, employees or other members of the public. We may also be required to disclose certain personal health information in order to maintain standing with professional health bodies, including those for pharmacists, audiologists and opticians.Personal health information may be stored by Toronto Naturopathic Clinic or Toronto Naturopathic Clinic Affiliates outside of Canada.
Personal health information may be stored by Toronto Naturopathic Clinic or Toronto Naturopathic Clinic Affiliates outside of Canada.
To ensure that the personal information and personal health information you provided is accurate, complete and up to date, we urge you to provide us with updates regarding such information and to inform us of any errors affecting the personal information and personal health information we hold. You may update, review or correct your Toronto Naturopathic Clinic online account information at any time by accessing your password-protected registration page via the “My Account” area of the Sites.
9. Security measures
We will continue to keep in place security measures in an effort to protect personal information and personal health information held by us from unauthorized use, access, disclosure, distribution, loss or alteration. Please be aware though that, despite these efforts, no security measures are perfect and no systems are impenetrable. Your privacy can be enhanced by taking care to use suitably strong passwords that others cannot guess, that are kept safe by you, and that are not re-used on other sites. Taking steps like avoiding dictionary words or proper names, and adding extra character and punctuation marks can also help protect you. If you believe your password has been compromised, you should change it immediately.
Access to personal information and personal health information will be restricted to authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties. We periodically update our policies regarding information security measures in an effort to protect the personal information and personal health information held by us in the most effective manner possible.
10. Online privacy practices
Collection: We may collect personal information and personal health information online when you visit our Sites.
Cookies help us to customize our web pages for you and to better display pages according to your browser type. While cookies are optional for browsing Toronto Naturopathic Clinic.com, they are required for registering, logging on, purchasing or adding items to your cart. If you wish to purchase items or set up an account on Toronto Naturopathic Clinic.com, you will need to accept a Toronto Naturopathic Clinic.com cookie. (In order to control the ability of website providers to place cookies on your computer, you should consult your browser’s “Options” and “Help” pages to learn how to adjust your settings to suit your privacy preferences.)
Use: We use personal information and personal health information collected online as described in Sections 5 and 7 above. In addition, we use personal information and personal health information:
· to facilitate and monitor certain features of the Sites that you choose to interact with;
· to respond to your questions and concerns and to understand your needs and preferences;
· to fulfill your online orders for products and services and to facilitate product deliveries, pickups and returns;
· to detect, prevent, or otherwise address fraud, security or technical issues; or
· to protect against harm to the rights, property or safety of Toronto Naturopathic Clinic, its users or the public as required or permitted by law.
Sharing: We share personal information and personal health information collected online as described above. In addition, we may provide Service Providers and product manufacturers and vendors with certain information that is necessary to fulfill an order you have placed with us. For example, if you request shipment for a purchase, we may provide your address to the shipping carrier and customs Service Provider, and if you pay by credit or debit card, your card number and sales transaction information are passed to the card processor and/or issuer (including their service providers such as fraud verification services). We also may use Service Providers to host and administer the Sites, process and store data, and fulfill other technology-related functions on our behalf. However, we only give or permit access to vendors, suppliers and other Service Providers involved in Site administration and the commerce distribution chain the limited information needed to perform their duties and provide you with the products and services you order. We are not responsible for any additional information you provide directly to these parties.
Protection: Personal information and personal health information we collect on our Sites is stored electronically, and may be combined with other off-line information. Personal information and personal health information entered on our Sites is encrypted using a security protocol called SSL (Secure Sockets Layer). SSL encrypts information entered on our site before it is sent over the Internet. SSL also allows you to view securely your online account and registration information. Account information is accessible online only through the use of a password. To protect the confidentiality of personal information and personal health information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Sites by any person using your password. You are advised that, unlike communication within our Sites, we have no control over the privacy of your email communications with us while in transit. We recommend that you do not include confidential, proprietary, personal or personal health information in emails, including credit card numbers, passwords, prescriptions and other similar information. Also, if other people have access to your email account, they may be able to access your password and obtain personal information about you (such as your credit card information), or change information about your user profile. You should not use an email account operated by your employer because many employers have the legal right to access such email accounts. Please advise us immediately by email at hello @ Toronto Naturopathic Clinic.com if you believe your password has been misused.