Application of Policy
This Policy describes Resolute’s (and its affiliates and subsidiaries, collectively “Resolute”) management of information, including the purposes for which we collect, use and disclose information and the safeguards we use to protect information. This Policy does not apply to the collection, use, retention, disposal, destruction, and protection of information by Manufacturer’s through the use of your PAP device. Manufacturers are subject to privacy legislation and professional requirements that govern their record keeping and management of information, regardless of the tools they use to collect, use, disclose and hold the information. Please direct any questions you have about how a Manufacturer will treat your information to the Manufacturer. For the purpose of this Policy the term “manufacturer” means the original equipment manufacturer of the PAP device.
What Personal Information Do We Collect?
If you are a patient, you may provide personal information to us, for example, when you attend at our clinic to complete a sleep study or when you begin your therapy. We require information from your physician such as medical information relevant to treatment of obstructive sleep apnea or other sleep disorders or your medical condition(s). We may collect information like this from you in person, when you speak to one of our staff on the phone or via video, through our website, from the device manufacturer software, your insurance company or when you communicate with us in any way in connection with the products and services we are providing. The information we collect will only be shared amongst Resolute personnel (including our employees, contractors and subcontractors), who have a need to know and access the information for the purpose, or in the course, of providing our products and services and to perform their designated functions.
You are not obligated to provide us with any information or participate in any of the products or services we offer. As such, we will consider any information we collect directly from you as having been provided voluntarily. If, however, you are unwilling to provide us with certain requested information, please understand that this may limit our ability to provide our products and/or services to you.
The information we may collect for all patients typically includes:
Information Manufacturers provide to us, and we provide to them: your ongoing and consistent use of the products and services we provide is critical to successful therapy. To ensure an optimal therapeutic experience we and the manufacturer have access to data from the PAP device that allows us to assess the quality and progression of your treatment.
How Do We Use Your Personal Information?
We may use the personal information we collect in several ways.
We typically use Patient data for the following purposes:
We typically use Manufacturer Data: (i) to store (and update when necessary) your details in our database (including adherence and usage data related to your PAP device) so that we can contact you in relation to your treatment, for the purposes of providing you with equipment and services; (ii) to send you information about our services, promotions, research, and any other information we believe you may find useful as it pertains to your use of a PAP device; (iii) to perform certain legal obligations; and (iv) to help us target appropriate marketing campaigns.
DATA COLLECTED VIA OUR WEBSITE
This Section applies to personal information that we collect and process through our website in the usual course of our business, such as scheduling appointments, answering your questions, selling/promoting our products and/or services and marketing activities.
What Personal Information Do We Collect?
Information you provide to us: Certain parts of our website may ask you to provide personal information voluntarily, for example, we may ask you to provide your contact details (like your name, email address, and phone number) to complete surveys, subscribe to marketing communications (like newsletters), submit inquiries, and/or otherwise communicate or interact with us.
We may also collect personal information from you offline, such as when you attend one of our events. You are not obligated to provide us any information or participate in any of the services we offer. As such, we will consider any information we collect directly from you as having been provided voluntarily. If, however, you are unwilling to provide us with certain requested information, please understand that this may limit your ability to participate in the services.
Information we collect automatically: When you visit our website, we may collect certain information automatically from your device. Such automatically collected information may include your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g., city-level location) and/or other technical information. We may also collect information about how your device has interacted with our website, including the pages or content accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors.
Some of this information may be collected using cookies and similar tracking technology.
How Do We Use Your Personal Information?
We typically use the personal information we collect through our website in the usual course of our business for the following reasons: (i) to respond to a request that you sent us, such as a request for information about our products or services; (ii) to inform you about general matters related to treatment; (iii) to administer, protect, and improve our website and our services; (iv) to better understand the preferences of our website visitors; (v) to compile aggregated statistics about website usage; (vi) to provide you with marketing and promotional communications (where this is in accordance with your marketing preferences); (vii) for other business purposes such as data analysis, identifying usage trends, determining the effectiveness of our marketing, and enhancing, customizing and improving our websites, products and services; and/or (viii) to authenticate you as a user of our website and to personalize your experience.
Cookies and Similar Tracking Technology
Links to Third Party Websites
How We Share Your Information
We may share your personal information in the following ways.
We share your information within Resolute operations (including our group of clinics and the clinical staff within those clinics). Your information is maintained on our corporate database and associated software, which is secure and accessible only to our employees across our business.
We may share your information with any medical professional who we understand is assisting in the treatment of your obstructive sleep apnea or other sleep disorder.
We may share your information with a competent regulatory or government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation.
In the case of a Manufacturer or other third-party service provider, we may share your information with those who will need to access or process your information for the purposes we have described herein.
We may share your information with a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Policy.
We may share your information with our marketing partners to send emails on our behalf.
We may share information with any other person with your consent.
Please be assured that we do not use your information for purposes that are incompatible with those set forth in this Policy.
International Data Transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of Canada (and, in some cases, may not be as protective).
Specifically, the manufacturer of your PAP device may have servers that are located outside of Canada. This means that when we collect your personal information it may be held on servers outside of Canada.
Your Data Protection Rights
You have the following data protection rights:
How Long Do We Keep Your Personal Information?
We will retain information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with our products or services or to assist your ongoing therapy).
If you have any questions about how long we retain your personal information, you may contact us using the contact details provided below.
How Do We Keep Your Personal Information Secure?
We take appropriate technical and organizational measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe, secure, and only available to you and to those with authorized access. If you have any questions about the security of your personal information, you may contact us using the contact details provided below.
Notwithstanding the safeguards we employ and our commitment to protecting information, we cannot guarantee the security or error-free transmission or storage of information. There are risks inherent in the use of electronic means to transmit and hold information in electronic format. These risks can be minimized but not eliminated using appropriate security measures, such as the measures Resolute employs. These risks include interception, loss, corruption, unauthorized access to, use and disclosure of information, and delay in the availability of information.
How To Contact Us
Please feel free to contact us with any comments, questions, complaints, or suggestions you might have regarding the information or practices described in this Policy.
You may contact us by sending a message to firstname.lastname@example.org You can also write to us using the details below: Resolute Health Corporation Limited Suite 208 – 120 Western Parkway Bedford, Nova Scotia B4B-0V2 Attention: Resolute Privacy Officer