Thoughtfile Inc. Privacy Policy

Last modified: November 16, 2016

Effective date: June 1, 2016


Terms of Use

Your use of this website, Thoughtfile.ca (the “Site”), is subject to this Thoughtfile Inc. (“Thoughtfile”, “we”, “us” or the “Company”) privacy policy (the “Privacy Policy”) as well as our Terms of Use found here. Terms capitalized but not defined in this Privacy Policy have the meanings set out in the Terms of Use.


Introduction to Privacy Policy

Thoughtfile is committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) of our subscribers and the information they provide while utilizing the Thoughtfile Software Product. The Company strives to support individual clinicians and clinics with the Thoughtfile Software Product, while respecting your own privacy expectations, as well as protecting your clients' privacy expectations (the “Privacy Expectations”). To demonstrate our commitment to protecting your Privacy Expectations, we have developed this privacy policy (“Privacy Policy”), which describes how we will collect, use, disclose and protect both your own Personal Information and your clients' Personal Information through the Thoughtfile Software Product.


Amendments to This Privacy Policy

The Company may amend or change this Privacy Policy, in its sole discretion, at any time, and in accordance with the amendment provisions set out in the Terms of Use. The use of the information we collect at any given point is subject to the Privacy Policy in effect at the time of collection.

In addition to being posted on the Website, this Privacy Policy is posted on the Thoughtfile Software Product, and your use of the Thoughtfile Software Product is subject to the most current Privacy Policy as posted on the Thoughtfile Software Product at any time. We encourage you to periodically check our Privacy Policy for the latest information on our current Privacy Policy.


Contact Information

If you have questions or concerns regarding our policy or practices, please contact our privacy officer by email at privacy@Thoughtfile.co.

If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you can contact the Privacy Commissioner of Canada at:


112 Kent Street,

Ottawa Ontario, K1A 1H3

1.800.282.1376

http://www.priv.gc.ca/


Collection of Personal Information
Collection of information at registration

Registration is required if you want to use the Thoughtfile Software Product. As part of this registration, we will require that you submit certain information that is relevant to providing the Thoughtfile Software Product. We collect the following information from our subscribers: registration information (first and last name, address, phone number, date of birth, gender, username, password, email address, clinic name and health care provider details) and credit card information (the “Personal Information”). Any information provided to the Thoughtfile Software Product relating to your clients' personal information (“Clients' Information” together with “Personal Information”, the “Information”) shall be restricted and not disseminated to any other party, except with individuals or entities required to provide the Thoughtfile Software Product.


Collection of information submitted by you

You may send electronic information or physical documentation to us in the following forms: messages or transaction information relating to your interactions with your clients, receipts, personal data in text and picture form; and other subscriber-generated content provided to us in the normal course of your use of the Thoughtfile Software Product and the Thoughtfile Social Properties, including but not limited to posts, profiles, comments, suggestions, forwarded messages, feedback information, usage information, transaction information and Traffic Data (as defined below).


Collection through interaction with the Thoughtfile Software Product

We may collect your Personal Information when you communicate it to us by use of one of our web forms or other interactions with the Thoughtfile Software Product, by email, or by any other means of communication (the “Aggregated Data”). Thoughtfile shall be entitled to anonymize the Aggregated Data, in its sole discretion, and utilize the Aggregated Data for benchmarking purposes.

Any information provided about potential clients shall be restricted. Thoughtfile shall not access such information except in order to provide the Thoughtfile Software Product, in accordance with the Terms of Use, and as required by any applicable law, rule, regulation, subpoena, or other legal process.

The Thoughtfile Software Product and the Thoughtfile Social Properties offer publicly-accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We take no responsibility for any information which you or your employees, agents, contractors and representatives post or publish on the Thoughtfile Software Product and you agree to indemnify and hold us harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from any such post or publication. We may post your testimonials along with your name on the Thoughtfile Software Product from time to time if such information is provided to us.


Traffic Data

“Traffic Data” is collected by the Thoughtfile Software Product and our third-party traffic analysis provider through the use of software that is included on the Thoughtfile Software Product as well as cookies that are stored temporarily on your computer. Together, these technologies help us manage our content by identifying which content is effective.


Use of Cookies and Usage Data

Cookies are small data files that are stored on a subscriber's computer for record-keeping purposes. Cookies track where you travel on the Thoughtfile Software Product and what you look at. A session ID cookie expires when you close your browser. When you log into the Thoughtfile Software Product, your browser may ask if you want it to remember you as a registered subscriber of the Thoughtfile Software Product. If you accept, the session ID becomes a persistent cookie, which remains on your hard drive for an extended period of time. Although cookies are used by most major websites and are accepted by default by most web browsers, it may be possible to disable cookies via your browser settings.

We use session cookies and usage data to make it possible to navigate the secure environment inside the Thoughtfile Software Product and to keep, and sometimes track, information about you for the purpose of creating a personalized web experience and improving the Thoughtfile Software Product or measuring and conveying to others the performance levels of the Thoughtfile Software Product. We may link the information we store in cookies to any personally identifiable information you submit while on the Thoughtfile Software Product for the purpose of creating a personalized experience within the Thoughtfile Software Product, to assist Thoughtfile in understanding its users and subscribers and designing improvements to the Thoughtfile Software Product and for the purpose of collecting Thoughtfile usage and performance metrics.


Use of analytics tools

The Thoughtfile Software Product may from time to time implement other third-party analytics services that also use cookies. We will ensure that no personally identifiable information is included in those cookies. If the use of cookies by any service provider differs materially from the practices already listed, we will revise this document accordingly and notify existing customers of the change(s). Other cookies created by the Thoughtfile Software Product are used to secure your login session and to help ensure the security of your account. Such cookies are unrelated to the aforementioned traffic analysis and are never shared with third parties.


Location Data

When you access the Thoughtfile Software Product using a web browser or other application, we may gather and store certain types of information including traffic data from your browser, your IP address, location, cookie information, and the pages you visit on the Thoughtfile Software Product. Traffic data is helpful in identifying and fixing problems with the Thoughtfile Software Product.


Use and Disclosure of Personal Information General Use

The Company will not use or disclose Information for purposes other than the identified purposes of the Thoughtfile Software Product. We may use your Personal Information listed above to:

• enforce our Terms of Use;

• provide customer service and support, resolve disputes, and troubleshoot problems;

• fulfill your requests for certain features of the Thoughtfile Software Product;

• customize, measure and improve the Thoughtfile Software Product;

• inform you of targeted marketing, service updates, and promotional offers unless you opt out;

• assist us to measure our performance and to share performance information with others;

• comply with legal or regulatory requirements (as described below); and

• fulfill other purposes, subject to your explicit consent.


Surveys

From time to time, the Company may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules for those contests, giveaways or promotions. From time to time, the Company may also ask you to participate in surveys designed to help us improve the Thoughtfile Software Product. Any Personal Information provided to the Company in connection with any Thoughtfilel be used only in relation to that survey and as elsewhere set forth in this Privacy Policy.


Acquisition of the Company

In the event that the Company, or all or a portion of our business, or one or more of its divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, liquidation or another similar transaction, your Personal Information shall be one of the transferred assets.


Legally compelled disclosures

Notwithstanding the foregoing, the Company reserves the right (and you authorize the Company) to share or disclose your Personal Information when the Company determines, at its sole discretion, that the disclosure of such information is necessary or appropriate:

• To enforce our rights against you or in connection with a breach by you of this Privacy Policy or the Terms of Use;

• To prevent prohibited or illegal activities; or

• When required by any applicable law, rule, regulation, subpoena, or other legal process.


Consent and Privacy Settings

By using the Thoughtfile Software Product, you consent to the collection, use and disclosure of your Personal Information by us in the manner described in this Privacy Policy. You may always opt not to disclose certain Personal Information, but that may mean that you will not be able to access certain features of the Thoughtfile Software Product. For example, your name and email address are necessary to complete the registration process. You may not opt out of most email communication from us as email is critical to ensuring appropriate administrative service are provided to you.

In addition, as described above, Thoughtfile is entitled to anonymize the Aggregated Data, in its sole discretion, and utilize the Aggregated Data for benchmarking purposes.


Accuracy of Information

The Company relies on you to ensure that the Personal Information you enter into our system is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You may make changes or corrections to your Personal Information at any time. If you would like to review or update your Personal Information, please contact our Privacy Officer at the contact details listed above.

We also make every effort to ensure the accuracy of the information in our reports, displays, articles and support queries. However, you must verify all information created from your use of the Thoughtfile Software Product and we recommend that you consult a professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk. You are responsible for ensuring that that the information you have entered into our system is accurate, reliable and complete.


Our Third Party Service Providers

We may share the Information with service providers who help us to run our operations or to otherwise fulfill your requests or as required by law. Our service providers are restricted from using the Information in any way other than for the service they are providing. We ensure that such service providers maintain reasonable and appropriate safeguards and we utilize our best efforts to ensure they sign confidentiality agreements or have similar confidentiality requirements included in their standard agreement. You own your data in accordance with the rules for Subscriber Content and Protected Content, as set out in the Thoughtfile Terms of Use, and can download your own data via the Thoughtfile Software Product at any time.


Link to Other Websites

Links to sites controlled or operated outside of our domain (each individually a “ Third-party Site” and collectively the “Third Party Sites”) are provided as a convenience to you only and do not imply an endorsement by us of a Third Party Site or the company it purports to represent. We do not assume any responsibility for information and materials found on, or the privacy practices of, a Third Party Site, and this Privacy Policy does not apply to a Third Party Site.


Security Measures

We take your privacy very seriously. Our security measures strive to adhere to PHIPA requirements as well as with the best practices of health care providers. To keep your Personal Information secure, you are required to safeguard your subscriber name and password information in accordance with the Terms of Use.

In order to keep the Information secure, we restrict unauthorized access through protective policies, procedures, and technical measures, including:

• encryption of your personal information using secure socket layer technology (SSL). To learn more about SSL, follow this link:

• providing reasonable physical and electronic safeguards with regard to the storage of the Information;

• limiting access to the Information to those employees or contractors who we reasonably believe need to come into contact with that information to provide products or services to you or in order to do their jobs; and

• governing employees and other contractors by strict standards and policies to ensure that the Information is secure and treated with the utmost care and respect.


In addition, Thoughtfile maintains the following physical safeguards:

• the office reception area is physically separate from the records processing area;

• access to both areas is key-controlled;

• access to the Information is restricted to required personnel only and access is monitored and recorded; and

• Thoughtfile pre-screens its employees, and provides training and orientation on their obligations to maintain the confidentiality and security of their client's records.


Please note that no data transmission over the Internet or otherwise can be guaranteed to be completely secure. As a result, while we strive to protect the Information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.


If you have a security related concern, please contact us at the contact details provided above. We will work closely with you to ensure a quick and personal response to your concerns.


Notifications

In the unlikely event that we believe that the security of the Information in our possession or control may have been compromised, we shall seek to notify you of that development. If a notification is appropriate, we may notify you by the email address registered to your account.

We will never send email messages to customers requesting confidential information such as passwords, credit card numbers, or social security or social insurance numbers. Please do not act on any such emails as you may compromise the Information by replying or by following links to a fraudulent website.


Miscelleaneous

If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator or court of competent jurisdiction, this Privacy Policy as a whole shall not be deemed unlawful, void or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or unenforceable shall be stricken from this Privacy Policy. The insertions of headings are for convenient reference only and are not to affect the interpretation of this Privacy Policy.