htx.ca - The Health Technology Exchange
Web site Legal Statements
www.htx.ca
PRIVACY POLICY
Welcome to the Health Technology Exchange web site ("www.htx.ca" or the "Web site"), operated by htx.ca - The Health Technology Exchange ("HTX" or "we"). Through the Web site, HTX acts as a catalyst for accelerating the growth of Ontario's Medical and Assistive Technologies ("MAT") industry cluster and ensuring Canada's position as a global leader in commercializing related innovation technologies. In doing so, we recognize the importance of privacy and the sensitivity of personal information and we are committed to providing our users and registered members with a Web site that respects their privacy. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.
Your Privacy Rights
From January 1, 2004, organizations engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA"). HTX is responsible for the personal information we collect, use, maintain and disclose. To ensure this accountability, we have developed this Privacy Policy, which adheres to PIPEDA, and trained our staff and affiliates about our policies and practices.
What is "Personal Information?"
Personal Information is any information that identifies you, or by which your identity could be deduced. It does not include your name, business address, business title, professional designation(s) or business telephone number.
Collection of Your Personal Information
We collect Personal Information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect Personal Information directly from you, but we may also obtain Personal Information about you from other sources. Personal Information may be collected, added to HTX's database and updated through completion of a Member Profile (described below). We generally ask you to provide necessary Personal Information through information forms, and may also use information from your Account (described below) based on your Web site visits or "quick surveys".
Use of Your Personal Information
We collect Personal Information from you in order for you to register with HTX. Most components and contents of the Web site are only available to users who register at www.htx.ca (each, a "Member") to create a Member account (an "Account").
When you register to create an Account you will be required to provide your name, address, e-mail address, telephone number and other personally identifiable information. Only HTX personnel, and occasionally, the Ministry of Research and Innovation ("MRI") for funding purposes, will be able to access Personal Information provided when you create your Account. Please note that the MRI is governed by the Freedom of Information and Protection of Privacy Act (Ontario) ("FIPPA").
Once you have an Account, you will be asked to provide user information which will be used to develop a Member profile ("Member Profile") that will be stored in an online database. You, or designated individuals from your organization, may update or modify your Member Profile at any time. Information such as (but not limited to) the name of your company or organization, its telephone number, e-mail address and web site, the type of business, industry, location, core competencies, and a categorization of the organization's functions, products and services, and any of your Personal Information that you choose to include, will be revealed as part of your Member Profile. You will also be provided with the tools to post personal certifications, appointments, resumés, images, opportunities, news stories, FAQ sheets, flat files, marketing documents and other information in your Member Profile, if you so choose. Any Personal Information you choose to include in your Member Profile may be accessed by HTX, MRI and other Members.
HTX may also use information from your Account based on your Web site visits or "quick surveys" to generate statistics and aggregate reports for HTX internal use, which may also be shown to affiliates of HTX and MRI. These statistics and aggregate reports will not contain any Personal Information and your identity will be kept anonymous. The data from statistics and reports will be used to track trends and patterns and will not be used to identify any entity or individual. Confidential information such as passwords are not disclosed in any of these reports.
With your permission, HTX may send you e-mail broadcasts related to upcoming opportunities in the MAT sector. If you tell us that you no longer wish to receive e-mails or information related to HTX, we will not send any further e-mails or information.
In addition, HTX may also use information from your Account and Member Profile to occasionally monitor traffic patterns, site usage and related site information in order to optimise the Web site, and in connection, we may provide aggregated information to third parties, but we will not include any identifiable Personal Information.
Other than as provided for in this Privacy Policy, HTX does not disclose your Personal Information to any third party to enable them to market their products and services.
HTX does not use your social insurance number as a way of identifying or organizing the Personal Information we hold about you.
We keep your Personal Information as long as is reasonably necessary for us to maintain your Account and Member Profile and to administer the Web site, or as may be required by law, whichever is longer.
Please note that the Web site may contain links to other web sites, which are not governed by this Privacy Policy. You should review the applicable terms and policies, including privacy and data gathering practices, of any web site to which you navigate from www.htx.ca, or relating to any applications you use or install from a third party web site.
Consent
In most cases, we will ask you to provide explicit consent if we collect, use, or disclose your Personal Information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your verbal consent. Sometimes, your consent may be implied through your conduct with us.
By registering for an Account, you consent to the disclosure of your Personal Information to HTX and MRI. By posting Personal Information in your Member Profile, you consent to the disclosure of such Personal Information to HTX, MRI and other Members.
Disclosure of Your Personal Information
Your Personal Information may be disclosed in the following circumstances:
· when we are required or authorized by law to do so, for example if a court issues a subpoena;
· when you have expressly or impliedly consented to the disclosure;
· when the services we are providing to you require us to give your Personal Information to a third party your consent will be implied, unless you tell us otherwise;
· where it is necessary to establish or collect amounts owed to us;
· if we engage a third party to provide administrative services to us (such as computer back-up services or archival file storage) and the third party is bound by our Privacy Policy;
· if the Personal Information is already publicly known;
· if MRI has received any Personal Information and is required to disclose it in accordance with FIPPA.
Security of Your Personal Information
HTX takes all reasonable precautions to ensure that your Personal Information is kept safe from loss, unauthorized access, modification or disclosure. We take certain steps to protect your Personal Information, including the following:
· premises security;
· restricted file access to Personal Information;
· deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
· internal password and security policies;
· we do not automatically gather any Personal Information from you - it is only obtained if you supply it voluntarily, usually through contacting us via e-mail, or registering for an Account in a secure portion of the Web site;
· any Personal Information you do provide is protected under PIPEDA.
· we do not regularly use "cookies" to track how users and members use the Web site, and whenever we enable "cookies" to facilitate your transactions, we will first inform you;
· your Personal Information is not disclosed to anyone without your prior express or implied consent, but will be used by HTX personnel in order to administer the Web site;
Updating Your Personal Information
Since we use your Personal Information to administer the Web site in relation to HTX's overarching purposes, it is important that all information be accurate and up-to-date.
You may update or modify your Member Profile at any time. Furthermore, if any of your other relevant Personal Information changes, please inform us so that we can make any necessary changes. If HTX holds Personal Information about you and if you can establish that it is not accurate, complete and up-to-date, HTX will take reasonable steps to correct it.
Access to Your Personal Information
You may request access to any Personal Information we hold about you.
Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.
Your rights to access your Personal Information are not absolute. We may deny access when:
· denial of access is required or authorized by law;
· when granting you access would have an unreasonable impact on other people's privacy;
· to protect our rights and property;
· where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request to correct Personal Information, we shall explain why.
Communicating with Us
You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send Personal Information or confidential information.
Additional Information
To see a copy of PIPEDA and its regulations, please go to:
http://laws.justice.gc.ca/en/P-8.6/.
To see a copy of FIPPA, please go to:
http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90f31_e.htm
For more information about how your Personal Information is used, and for more information about HTX and standards of conduct for the Web site, it is strongly recommended that you review our Terms of Use.
If you have any comments or concerns about privacy at www.htx.ca and/or your Personal Information, please contact us at admin@htx.ca.
Changes to Privacy Policy
HTX reserves the right to change the Privacy Policy, Terms of Use and other rules and guidelines posted on the Web site from time to time in its sole discretion, and will provide notice of material changes on the home page of the Web site. You should periodically check the Privacy Policy and Terms of Use links on the Web site's home page to view the then-current Privacy Policy and Terms of Use.