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Privacy Policy
1. OUR PRIVACY ASSURANCE
Sole Solutions +. (“SS+”), is committed to protecting your privacy and has implemented policies and procedures to ensure that your personal information is handled securely and in accordance with applicable privacy laws, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). As part of our information handling practices, SS+ has developed this Privacy Policy in order to keep you informed of the ways in which we collect, use and disclose personal information. Our Privacy Policy may be revised from time to time to reflect our evolving business and the nature of the products and services we offer to you. To ensure that you are aware of our current privacy practices, we recommend that you review this policy periodically. Should you choose to provide us with your personal information, you will be deemed to have agreed with the terms and conditions contained in this policy. This Privacy Policy applies when you interface with us online at www.phoenixmeddirect.com, (the “Site”), processing your orders, responding to requests for assistance or information, creating and improving our products and services, suggesting additional or different products or services and protecting our rights and property. While our Sites may provide links to third party websites, we accept no liability for the third parties’ treatment of your personal information and their activities. Any information you choose to provide to these third parties is not administered by this Privacy Policy, and SS+ is not responsible.
2. PERSONAL INFORMATION
The term “personal information” refers to any information that specifically identifies you as an individual and may include details such as your name, e-mail and mailing addresses, telephone and/or fax numbers, credit card information, as well your purchasing history/habits if they can be linked to you. SS+ needs to collect certain types of personal information from you to provide you with products and services that you request through our Sites or as otherwise described in this Privacy Policy. Should you decline to provide such information, SS+ may not be able to provide you with certain products or services. SS+ may also use “non-identifiable information” in order to compile broad demographic and website usage information about our consumers in general that cannot or will not be used to identify you personally. This non-identifiable information is in the form of anonymous, aggregate data and consumer patterns gleaned from your computer’s web browser when you visit us online. Such information may include your Internet address, the address of the website you are coming from, the amount of time you spend visiting our website, the pages visited, the operating system and web browser software you use, and, if you link to us through a search engine, the keywords you use to find our website. The logs do not record personal information, can be accessed only by SS+, and are used solely to track visits to our site, improve its content and layout and to achieve a better understanding of our customer in general. SS+ never attempts to tie this information to particular individuals visiting our Site.
3. CONSENT
SS+ obtains your consent to collect, use or disclose your personal information, except as otherwise permitted by law. The method of obtaining consent depends on the circumstances and the sensitivity of the information. Consent may be oral or written, express or implied. Your express consent (verbal, written or electronic agreement) is obtained to collect, use or disclose sensitive personal information. Implied consent is obtained in circumstances where a customer relationship already exists, express consent has previously been given, or the purpose of using the personal information is reasonably apparent to you. If you decide that you do not want to receive marketing offers for products and services, you may always withdraw or refuse your consent at any time by clicking the “unsubscribe” option in our emailed materials or contacting our Privacy Officer at the contact information provided below. Your request will be promptly processed but may not be processed in time to remove you from promotions already in progress. If you decide to withdraw or refuse your consent, our ability to communicate with you will be diminished. For example, we will generally not be able to tell you about products and services that may be of value to you.
4. COLLECTION AND USE OF PERSONAL INFORMATION
SS+ needs to collect, use and disclose certain types of personal and non-identifiable information in order to process orders placed through our Sites, to respond to requests or to otherwise administer its relationship with its customers. The personal information we collect for these primary purposes will only be used with your consent and only in accordance with this Privacy Policy, as required to carry out these activities. For example, SS+ will need to collect, use and disclose personal information in order to:
a) process your application for a product or a service;
b) better understand your product and services needs and to offer relevant information, products, services and rewards to meet those needs;
c) determine your interest and eligibility for, and where appropriate provide you with, products and services;
d) advise you when delivery of products and services are available;
e) track and analyze your purchases, other transactions, shopping patterns, account activity for marketing analysis purposes; or
f) making promotional offers to you;
g) conduct surveys and analysis for research, statistical and product development purposes (information will be anonymized to the extent possible);
h) verify your identity and protect against error and fraud;
i) process, service, analyze and audit your relationship with us;
j) support promotions and contest administration;
k) perform tests to implement or modify systems;
l) comply with legal and regulatory requirements; and
m) achieve other purposes as may, from time to time, be permitted by law.
By providing your information to SS+, you consent to SS+ using your personal information for the purposes outlined above. Please be assured that SS+ will only collect information that is necessary for the purposes which have been identified and that we will obtain your consent for any additional and different uses of your personal information, where required.
5. TRANSFER OF PERSONAL INFORMATION
We may transfer your personal information to entities outside SS+, such as our vendors, suppliers, freight carriers and agents (“Service Provider(s)”) who assist us in serving you. When your personal information is transferred to a Service Provider, we require them to protect the information in a manner that is consistent with this Privacy Policy. Our Service Providers may be located outside of Canada and may be required to disclose your personal information under the laws of their jurisdiction. You may contact us for information about our policies and practices regarding Service Providers to whom we have transferred your personal information and their locations (see the SS+ Privacy Officer’s Contact Information, below). SS+ retains your personal information only as long as required for our business relationship or as required by law. In the unlikely event that SS+ or substantially all of any of its assets are acquired by an unrelated third party, your personal information may be one of the transferred assets. By providing your personal information to us, you agree that we may disclose your personal information, on a confidential basis, to any prospective transferee and its professional advisors for the purposes of their due diligence investigations, the completion of any such transaction and the continued operation of the acquired business.
6. MARKETING AND PROMOTIONAL PURPOSES
From time to time, SS+ may use personal information to inform you of additional offerings or developments, to better identify products and services that may be of interest to you, or for other marketing and promotional purposes, for example, or to provide you with current information about SS+’s business activities. Should you choose not to provide your consent to these activities, SS+ will refrain from using your information in this manner. You may at any time indicate that you do not wish to receive such information by clicking the “unsubscribe” option in our e-mailed materials or by contacting our Privacy Officer at the Contact Information provided below.
Outside of these marketing and promotional communications, SS+ will need to communicate with you, from time to time, concerning our business relationship and to advise you of important changes concerning SS+ and/or the Sites. These communications are essential customer notification services and will not include promotional or marketing communications. Please be assured that SS+ will not distribute, rent or sell any personally identifiable information to third parties without your express consent, unless required by law or otherwise in accordance with this Privacy Policy.
7. DISCLOSURE OF PERSONAL INFORMATION
Our employees are familiar with the contents of this Privacy Policy and are informed about our policies and procedures for protecting personal information. Your personal information is only disclosed to those within SS+-owned or affiliated companies with a need to know, which individuals are held accountable for maintaining the confidentiality of all personal information to which they have access.
8. SECURITY MEASURES
SS+ has established safeguarding measures to uphold the security of personal information obtained from and about you, regardless of the format in which it is held. We have instituted policies and procedures to protect against unauthorized use or access, alteration, duplication, destruction, disclosure, or loss or theft of your personal information. All electronically-stored or transmitted personal information resides on secure servers behind a firewall and database access is carefully restricted.
9. ACCESSING YOUR PERSONAL INFORMATION
You may access personal information SS+ has collected about you. Should you wish to review or verify your personal information, please refer to the contact information provided at the end of this Privacy Policy. At the time you make such a request, we will need specific information from you to enable us to search for, and provide you with, the personal information we hold about you. There may be instances in which we will be unable to provide full disclosure of the personal information we hold about you. These include, but are not limited to, cases where personal information:
a) contains references to other persons;
b) is subject to solicitor-client or litigation privilege;
c) contains our own proprietary information that is confidential to us;
d) has already been destroyed due to legal requirements, or because we no longer needed it for the purposes set out in this Privacy Policy; or
e) cannot be disclosed for legal reasons.
If we are unable to provide you with access to your personal information, you will be notified and provided with an explanation.
10. CHANGE IN OWNERSHIP
In the event that SS+ or any of its assets are acquired by a third party, personal information acquired by SS+ may be one of the assets transferred.
11. CONTACT US
We are committed to maintaining the accuracy of your personal information for as long as it is being used for the purposes for which it was collected, and provided that you notify us of any changes. Prompt notification of changes in information, such as your e-mail or mailing addresses, will assist us in providing you with the best possible service. Upon request, SS+ will provide additional information about this Privacy Policy and our information practices and procedures in order that you have a better understanding of our collection, use and disclosure of personal information.
For further information, please contact our Privacy Officer at:
Email: [email protected]
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