ICE Privacy Policy

ICE HEALTH SYSTEM PRIVACY POLICY

This personal information and privacy policy was last updated on March 5, 2015.

Important Notice: ICE Health Systems Inc. and its related companies (collectively, “ICE“) consider matters relating to the protection of your personal information and your privacy to be extremely important.   ICE has created and implemented this personal information and privacy policy (the   “Privacy Policy“) so that you understand how your personal information may be utilized and how it is protected. ICE encourages you to review this Privacy Policy. By providing personal information to us and by dealing with ICE, we will assume that you have consented to the collection, use and disclosure   of your personal information in accordance with the terms set out in this Privacy Policy unless you  advise us otherwise. This Privacy Policy is subject to the terms and conditions of the ICE/ Institution Agreement (as defined below). For the avoidance of doubt, nothing in this Privacy Policy is intended to undo or otherwise remove or limit in whole or in part any prohibitions or restrictions with respect to ICE’s use and disclosure of your personal information or the information of your Institution set forth in the ICE/ Institution Agreement. If you have questions regarding this Privacy Policy or our privacy practices then please contact our Privacy Officer, whose contact information is set out at the bottom of this Privacy Policy.

Amendments to this Privacy Policy

Subject to certain restrictions in the ICE/Institution Agreement, ICE may amend this Privacy Policy from time to time as ICE may decide in its reasonable discretion. The first sentence of this Privacy Policy indicates when the Privacy Policy was last amended. Please check back regularly for changes.

ICE/Institution Agreement

ICE has been engaged under a separate agreement (the “ICE/Institution Agreement“) that ICE has with your institution (the “Institution“) to make available to you the ICE Health System and certain related services (collectively, the “ICE Health System“).

Our Commitment

Except as otherwise described in this Privacy Policy, ICE will not sell, rent, loan, trade, lease, transfer   or otherwise disclose your personal information, including e­mail addresses, to any third party. For the avoidance of doubt, your Institution shall not be deemed a “third party” under this Privacy Policy.

Definitions

In this Privacy Policy, the following term has the following meaning:

personal information” means information about you. Personal information does not include information that cannot be attributed to you. For example, information of an aggregate or

anonymous nature is not personal information under this Privacy Policy and, therefore, is not subject to the terms of this Privacy Policy.

Consent

Except as otherwise described in this Privacy Policy, we will obtain your consent to our collection, use and disclosure of your personal information. This consent may be explicit or implied and the consent  may be given orally or in writing, depending on the circumstances.   In particular, we will not obtain  your explicit consent to certain uses and disclosures of your personal information if such disclosure is required by applicable law, is commercially reasonable and/or it is customary industry practice to make such disclosures.   In the instances specified in the immediately preceding sentence, your consent will   be implied.

Notwithstanding the foregoing, in those cases where we are handling sensitive personal information,  such as your health information, or where the uses or disclosures of your personal information are not required by applicable law, are not commercially reasonable and/or it is not customary industry practice to make such disclosures, we will ask you directly for your consent to those uses or disclosures if you have not previously provided us with consent for the same.

When obtaining your consent we will inform you of the uses and disclosures that we wish to make of your personal information unless those uses and disclosures are set out in this Privacy Policy.

In the event a new need arises for the use or disclosure of previously collected personal information, except as otherwise described in this Privacy Policy, we will obtain a new consent for the new use or disclosure prior to commencing that use or disclosure.

Changing Consent

You may change or withdraw your consent at any time on reasonable notice, subject to pre­existing legal and contractual obligations, by contacting our Privacy Officer as set out below. However, if you withdraw certain consents, it may limit the manner in which you can make use of ICE’s services or otherwise interact with ICE.

For clarity, your ability to change or withdraw consent is not absolute. Despite a change or withdrawal  of consent, ICE reserves the right to continue handling your personal information in those   circumstances required by law, when any prior action has been taken or commitment given in reliance  on your consent, in connection with a possible unauthorized access or a possible attempt to gain unauthorized access or other possible illegal activity or breach of the Terms of Service.

Collection

For users of the ICE Health System, you or your Institution will be inputting your personal information into the system. For patients, your care providers will be inputting your personal information and heath information into the system.  Patients may also be provided the opportunity to input their information  into the system.

In other circumstances, where practical, we will try to collect personal information directly from you. Occasionally, we may need to collect personal information from other sources. In those circumstances, we will have those third parties verify that they are entitled to disclose your personal information to   ICE.

Use

By agreeing to this Privacy Policy, your consent will be deemed to be explicitly given to the following uses of your personal information:

  • in connection with any use of our services, we may process, store and archive your personal information;
  • in connection with our ongoing evaluation and improvements to our services and systems, we may analyze how you are using the services, and incidental to that analysis, we may review some of your personal information in connection with such evaluation and improvements;
  • using identification information and contact information, such as your name, address, telephone number and e­mail address to provide information about ICE and its services when you request that information;
  • using identification information and contact information, such as your name, address, telephone number and e­mail address so that we can identify you and communicate with you in    connection with our operations;
  • subject to the restrictions set forth in the ICE/ Institution Agreement, using customer and/or supplier relationship information such as your service requests, instructions and comments to assist us in delivering services in accordance with your wishes; and
  • using personal information for the purpose for which it was provided and certain other related activities reasonably needed for management of the ICE Health System and our relationship.  For example, if we think there may be an error in the personal information contained in one of records we may use your contact information to contact you regarding that error. As an additional example, we may use the content of your email to make changes to our products and services if you email us with a complaint about some aspect of our products or services.

Disclosure

Subject to certain restrictions in the ICE/Institution Agreement, by agreeing to this Privacy Policy, your consent will be deemed to be explicitly given to the following disclosures of your personal information:

  • In the event ICE transfers control of any or all of its operations or assets to another    organization, ICE reserves the right to transfer and/or disclose your personal information to that organization. However, ICE will require that the organization agree that it will be similarly  bound by the provisions of this Privacy Policy and that it will only use and disclose your  personal information as ICE is similarly entitled under this Privacy Policy; and
  • ICE may work with other organizations to integrate their services into our service offerings as may be contemplated in the ICE/Institution Agreement. ICE may disclose your personal information to these other organizations solely to the extent necessary to perform such third­party service integrations. ICE will require that these organizations agree in writing that they will only use and disclose your personal information as necessary to integrate their services into ICE’s service offerings and that they will adhere to the terms of this Privacy Policy (as if such organization had entered into this Privacy Policy rather than ICE) and terms regarding use and disclosure of personal information at least as restrictive as those set forth in the ICE/ Institution Agreement.

Service Providers

ICE may engage certain service providers, including, without limitation, security auditors and data storage services. Those service providers may provide services to ICE to assist ICE in its activities.  Other service providers may provide services directly to you at the request of ICE. As such, it may be necessary for ICE to disclose your personal information to these service providers. However, ICE will require that these service providers agree that they will only use and disclose your personal information as necessary to provide the services and that they will adhere to the terms of a privacy policy which is similar to this Privacy Policy. As well, some of these service providers may assist ICE in the collection  of your personal information. ICE will require that these service providers agree that they will not  collect, use or disclose your personal information for any other purpose and that they will adhere to the terms of a privacy policy which is similar to this Privacy Policy.

Other Collection, Use and Disclosure

Subject to applicable law, we may collect, use and disclose your personal information without your knowledge or consent in some specific and limited circumstances as set forth in this Section.   We  reserve the right to collect, use and disclose your personal information in these limited circumstances without your knowledge or consent. ICE may monitor your use of its services to ensure the proper use and operation of those services. As well, we may collect, use and disclose your personal information without your knowledge or consent when that personal information is relevant to an actual or potential legal proceeding involving ICE, Institution and/or you or when we are required or permitted to do so by court order, applicable law or regulatory requirements.

Notwithstanding the foregoing, where privacy law permits the collection, use or disclosure of personal information without your knowledge or consent, ICE will only do so in connection with the following:

  1. a possible unauthorized access or a possible attempt to gain unauthorized access to ICE’s systems or any data or personal information stored on such systems; or
  • in respect of a possible illegal activity or breach of the Terms of Service.

Use of the Website

In order to use some of the features of ICE’s website, ICE may require that you provide some personal information. Our web server collects the domain names, IP addresses and the website activity of  visitors. This information is aggregated for the purposes of measuring the number of visits, average

time spent on the website, pages viewed, and other similar purposes. ICE uses this information to measure the use of our website and to improve the content of our website.

A technology called cookies may be used on certain pages of our website.   A cookie is a tiny element   of data that a website can send to your browser, which may then be stored on your hard drive so the website can recognize you when you return. Cookies allow us to provide you with tailored information and to provide services to you via the Internet. If your browser permits, you may set your browser to notify you when you receive a cookie or to reject cookies altogether. (See the documentation provided with your Internet browser for more information on cookies and how to disable them.)

Accuracy and Completeness

When we collect, use or disclose personal information, we will make a reasonable effort to ensure that  it is accurate, up to date and complete. To do so, we may need to request additional information from you or have you verify your information. If your personal information does change, we would appreciate it if you could inform us of those changes in order that your personal information in our possession remains accurate.

Retention  and Destruction

Subject to applicable law and certain restrictions in the ICE/Institution Agreement, for legal and business purposes we may retain your personal information for as long as it is reasonably needed. Upon expiry of the appropriate retention period, bearing in mind our reasonable legal and business requirements, your personal information will either be destroyed in a secure manner or made anonymous. You should be aware that there are legally required minimum retention periods, which ICE must and does observe.

Security of Personal Information

ICE recognizes its obligation to protect personal information in its possession. Therefore, ICE will  make arrangements as may be required by law or as may be reasonable in the circumstance, whichever  is the higher standard, to secure that personal information against unauthorized access. Depending on  the circumstances, these measures may include providing access to only those individuals with a need   to know the information, locked doors and/or filing cabinets and other physical and electronic security measures as well as contractual measures, such as non­disclosure agreements.

Limited Nature of this Privacy Policy

Nothing contained in this Privacy Policy is intended to create a contract or agreement between ICE and you and you may not rely on it as such.

Contacting or Communicating With Us

If you:

  • have any questions with respect to our privacy policies or practices;
  • have any questions with respect to our handling of your personal information;
  • wish to correct any of your personal information under our care or control; or
  • are dissatisfied with our handling of your personal information or any response we may have given,

please contact our Privacy Officer at: ICE Health Systems Inc

120, 1289 Highfield Crescent SE Calgary, Alberta T2G 5M2

Fax: (403) 313­9201 OR E­mail: privacy@icehealthsystems.com

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