PHEBRA CANADA PRIVACY POLICY
This Privacy Policy applies to residents of Canada only.
Phebra’s Commitment to Privacy
Phebra Canada Inc (Phebra Canada) is committed to responsible privacy practices, and is bound by all applicable Canadian privacy laws, including the Personal Information and Electronic Documents Act. This Privacy Policy explains how Phebra Canada collects, uses, discloses and safeguards the personal information that you provide to it on websites controlled by Phebra Canada. By accessing and using Phebra Canada’s websites, you accept the terms and conditions contained in this policy. References to Phebra Canada in this policy encompass its employees, agents, contractors and affiliates.
How Does This Privacy Policy Define “Personal Information”?
“Personal information” means information that identifies you or could reasonably be used to identify you and which is submitted to and/or collected by Phebra Canada’s websites and maintained by Phebra Canada in an accessible form, in the course of its commercial activities. Examples of personal information include your name, your postal address and your telephone number.
How and Why Phebra Canada Collects and Processes Personal Information
Phebra Canada may collect and hold information about individuals who may be customers, members of the general public, job applicants, business contacts, healthcare professionals and others. Personal information will only be collected if it is necessary for Phebra Canada’s work, and will be collected fairly and lawfully.
Examples of personal information which may be requested and/or voluntarily submitted to Phebra Canada on its websites include name, postal address, email address, telephone numbers. Generally, this will be in the form of information you enter into data fields on Phebra Canada websites.
Your Personal Data may be collected to fulfill services that you have requested and to understand your interests and preferences. In these instances, Phebra Canada may collect your contact information as well as a history of your previous transactions with it (such as order history, customer account information). If you are purchasing or ordering a product or service from Phebra Canada, this information will be used to fulfill your order.
To protect your privacy, you should not provide Phebra Canada with any information which is not specifically requested.
Phebra Canada may also collect passive, non-identified information from you whilst you are accessing Phebra Canada websites without you actively submitting such information. Such non-identified information may be collected by Phebra Canada or by its advertising and marketing partners using technologies such as cookies. A cookie is a small data file that is placed on a user’s computer when a particular website is accessed. Cookies by themselves cannot be used to discover a user’s identity and simply act as a memory for a website, enabling that website to remember a user’s computer on return visits. Individuals have the ability to accept or decline cookies, however, if declined, some areas of the website may not function fully. Phebra Canada may use cookies to collate anonymous, aggregated statistics to enable us to understand how our website is used.
The section below entitled “Web Analysis” has more information about how Phebra Canada conducts uses automated technologies to collect your non-identified information.
Accessing Phebra Canada’s Website
You can access Phebra Canada’s website without disclosing your personal information. You are not required to provide personal information as a condition of using this website, except as may be necessary to provide you a product or service at your request.
Storage and Security
Phebra Canada will take responsible steps to ensure that all personal information is captured, managed, stored and transmitted in accordance with Canadian privacy laws. It will be stored securely to prevent its loss or misuse, unauthorised access, its modification or disclosure.
Personal Information you share with Phebra Canada is stored on database servers at Phebra data centres (in whatever country they may be located) or hosted by third parties who have entered into agreements with Phebra that require them to observe this Privacy Policy. Data centres are designed to be physically secure and protected from unauthorized access by unauthorized persons. Personal Information is stored for as long as is necessary to fulfill the purposes for which the information was collected and to comply with legal requirements.
Access to personal information is limited to a restricted number of Phebra employees, who may be Phebra Canada employees or employees of other Phebra affiliates. Phebra Canada and its affiliates will not use or disclose personal information to third parties, without an individual’s consent, for purposes other than those listed below, and at all times your Personal Information will only be collected, processed, transferred or stored in accordance with this Privacy Policy or privacy policies of Phebra affiliates which are no less onerous.
– to supply a service or product which has been requested
– when permitted under an agreement with or consent of the individual
– to lessen a serious threat to a person’s health or safety
– when required by law or for the enforcement of law
– emergency situations.
Phebra Canada will not provide your personal information to any third party for that party’s independent use. However, Phebra Canada also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Phebra Canada or of any of the business or assets or shares of Phebra Canada or a division thereof.
Protection of Children Online
Phebra Canada considers the protection of children’s privacy, especially online, to be of the utmost importance and does not knowingly collect or solicit personal information from children nor does it knowingly allow them to become registered users of, or to request information through, Phebra Canada’s websites or help-seeking information lines.
Web Analysis
Our website uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
Google will analyse your use of our website on our behalf. To this purpose, we use, among others, the Cookies as described above. The information collected by Google in connection with your use of our website (e.g. the referring URL, which of our webpages you visit, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the United States, where it will be stored and analysed on behalf of Phebra; the respective results will then be made available to Phebra in an anonymised form. In this process, your usage data will not be connected to your full IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures an adequate level of data protection with respect to the processing of data by Google in the US.
You may opt-out from the use of web analysis at any time by downloading and installing a Browser Plugin offered by Google or by managing your preferences via an opt-out cookie, which will be set if you choose not to use cookies. Both options will prevent the use of web analysis only if you use the browser on which you installed the plugin or if you do not delete the opt-out cookie.
For further information on Google Analytics please refer to the Google Analytics Terms of Service, the Google Analytics security and privacy principles, and the Google Privacy Policy.
Links to Other Websites
Phebra Canada’s website contains links to third party sites as a service to users. Phebra Canada does not endorse or warrant anything in relation to linked third party websites. Access to linked third party websites is entirely at the individual’s risk. Phebra Canada’s Privacy Policy and the privacy statement outlined here does not pertain to those external sites.
Privacy Policy Changes
From time to time it may be necessary for Phebra Canada to review and revise its Privacy Policy. Phebra Canada encourages you to periodically check its website, where Phebra Canada will post the most up-to-date version of its Privacy Policy.
What If You Have A Complaint?
If you have any concerns or complaints about the manner in which your personal information has been collected or handled by Phebra Canada, please contact the Privacy Officer. Your concern or complaint will be directed to the appropriate manager to consider and respond to your complaint.
Contact Us
If you have questions about Phebra Canada and privacy, wish to provide feedback about our Privacy Policy, would like to update your personal details held by Phebra Canada or wish to access or correct information held by Phebra about you, please contact the Privacy Officer at:
The Privacy Officer
Phebra Canada Inc
7171 Frederick-Banting
Montreal (Québec)
H4S 1Z9
Canada
Phone: 1-888-902-8383
Or by email: privacy@phebra.com
Last updated 21 January 2020