Our Privacy Philosophy
For the purposes of this Policy, “personal information” means information that can identify an individual directly or through other reasonably available means. “Personal information” does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession. Notwithstanding anything to the contrary herein, the meaning of “personal information” shall be interpreted in a manner that conforms with the minimum requirements of applicable privacy legislation.
Identifying Purposes and Obtaining Your Consent
We identify the purposes for collecting personal information at or before the time it is collected. We will not collect, use or disclose your personal information without your informed consent, unless required or permitted to do so by law.
At PIMs+, we collect and use personal information so we can: (i) provide, maintain, and improve our products and services, which includes using the information to allocate resources, and otherwise run and manage PIMs+ in the ordinary course; (ii) provide information to our employees, contractors, partners (which are deemed in this Policy to include McMaster University, on behalf of its Department of Family Medicine, and the American Society of Consultant Pharmacists) and affiliates to allow them to perform services on our behalf, including the provision of personal information to service providers engaged by PIMs+; (iii) send you newsletters or other communications to which you have subscribed or may be interested; (iv) comply generally with privacy laws and all other applicable regulatory requirements; (v) understand the demographics, interests, usage patterns, and other characteristics of customers and to track and analyze trends and patterns, including through the aggregation of personal information; (vi) administer surveys; (vii) offer you tailored content, including advertisements; and (viii) assist you when you contact our customer support services, including to direct your questions to appropriate individuals, investigate and address any of your concerns, and to improve and monitor our customer support responses. We may also use your personal information for purposes that are otherwise consistent with the terms of this Policy or that are permitted or required by law, and for purposes for which you have otherwise provided consent.
Should we require your information to fulfill a purpose that is not identified in this Policy, we will obtain your consent before proceeding.
Limiting the Collection, Use and Disclosure of Your Personal Information
a) The information we collect
The type of personal information that we may collect, including when you register for an account, includes: (i) your name, mailing address, email address, and telephone number; and (ii) other information that you share in your communications with us, our employees, our contractors, or our partners, including on or through the Website and any applications available on the Website.
The choice to provide us with your personal information, either directly or through a third party, is yours. However, your decision to withhold particular information may limit our ability to provide you with some of our products or services.
b) How your information is collected
Personal information may be collected in a number of ways, including: in person, over the phone, by mail, by fax, over the Internet (including from our Website, by email, or through any of our applications or other software that we provide), and from third parties whom you have authorized to disclose personal information to us.
If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.
Your personal information will only be used or disclosed in accordance with the purposes for which it was collected, unless you have otherwise consented or except where required or permitted by law.
c) We may monitor and record telephone calls
For the purpose of maintaining quality service, telephone calls to our customer service lines may be recorded. If your call is subject to a quality assurance program, you will be so advised prior to speaking with a representative.
d) Disclosure to third parties
We may share your personal information with our service providers in order for them to provide services to or on behalf of PIMs+, including processing and storage. These may include, for example, cloud storage providers and data analytics providers. To that end, when you provide personal information to PIMs+, the information may be stored on servers hosted or owned by a third party.
We may (i) share your personal information with our affiliates and partners; (ii) combine information internally across our affiliates or our different products and services; and (iii) combine personal information with demographic information, publicly available records and other third party information sources. We may use this information to provide you with a customized experience, to promote and develop products and services available through PIMs+ or its affiliates, or as otherwise permitted by this Policy.
If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Website or other applications, your communications may be viewable by the public.
We may also disclose personal information in situations where we are legally required or permitted to do so. The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements or to enforce your rights or to investigate suspicion of unlawful activities. In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property or safety of ourselves and others.
We may use and disclose your personal information to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing personal information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your personal information for substantially the same purposes as those set out in this Policy.
We may share Personal Information in the aggregate with third parties. For example, we may disclose the number of users that have been exposed to or clicked on advertisements. We may also disclose anonymized information about your use on PIMs+. For example, if you engage in a transaction in connection with PIMs+, we may publicly disclose information about the transaction in a manner that does not disclose Personal Information.
e) Keeping your information accurate
We make every reasonable effort to keep your personal information as accurate, complete and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records.
Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
Protecting Your Personal Information
a) Access to your information within PIMs+
Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees or contractors with legitimate business reasons.
Our employees and contractors understand the importance of keeping your information private. All employees and contractors are expected to maintain the confidentiality of personal information at all times and failure to do so will result in appropriate disciplinary measures including dismissal.
b) Disposal and Retention
Except as otherwise permitted or required by law, your personal information will be retained for so long as is reasonably necessary to fulfil the purposes for which it was collected.
c) Safeguarding your information
To ensure that your personal information is protected, we utilize security safeguards that are on par with the industry standard. We keep electronic customer files in a secured environment with restricted access and use.
Addressing Your Inquiries and Concerns
We are happy to provide you with a copy of this Policy.
Upon request, we will also inform you of: the type of personal information we have collected, how your personal information has been used, and any third parties to whom your personal information has been disclosed.
Please direct all questions or enquiries about this Policy to:
Data Based Medicine Americas Ltd.
181 Bay Street, Suite 1800
Toronto, ON, M5J 2T9
PIMs+ strives to evolve to meet our customer’s needs and expectations, and that means our products and services may change, and how we offer our products and services may change. With that in mind, we review our privacy practices from time to time, and that our information handling practices may change. Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner. PIMs+ reserves the right to change, modify, add, or remove portions of this Policy at any time. Please check this page periodically for any modifications. To determine when this Policy was last updated, please refer to the modification date at the bottom of this Policy. If at any point you do not agree with the terms of this Policy, you must not use PIMs+’s services.
Our Website and any of our applications available from our Website or third party platforms (including the iTunes Store and Google Play) are governed by the provisions and practices stated in this Policy. Our Website and such applications may contain links to third party sites or applications that are not governed by this Policy. Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Website or such applications, and that we are not responsible for the privacy practices of third party sites or applications. We therefore suggest that you closely examine the respective privacy policies of third party sites and applications to learn how they collect, use and disclose your personal information.
This Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.
Personal Information Outside of Canada
PIMs+ may perform activities outside of Ontario and outside of Canada through third parties. For example, personal information may be stored on servers outside of Ontario and outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.
Last revised: Tuesday, August 25, 2020