We Value Your Privacy
At Tuolc Inc. (“Get Truman”), we are committed to protecting your privacy and safeguarding your “Personal Information” (defined below). Personal Information will only be collected and retained for legitimate purposes. It will be necessary to collect and use Personal Information about our customers when they view our Get Truman website (the “Get Truman Site”) or when providing our services.
The purpose of this Privacy Statement is to inform you about the types of Personal Information Get Truman (as follows, “we” or “us”) collects, uses and discloses in connection with the Get Truman Site. It explains how we use and disclose that information, how the information is protected, the choices you have regarding such use and disclosure, and how you may correct that information.
We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, and specifically the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Health Information Protection Act (Ontario) and the regulations thereunder.
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently.
The following topics will be covered in this Privacy Statement:What is Personal Information? How do we collect your Personal Information?
Where do we store your Personal Information? How do we use your Personal Information?
To whom do we provide your Personal Information?
When and how do we obtain your consent? How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
How long will we utilize, disclose or retain your Personal Information?
How can you review your Personal Information that we have collected, utilized or disclosed?
How do you know that the Personal Information we have on you is accurate? What if the Personal Information we have on you is inaccurate? How fast will we respond to your written requests?
Are there any costs to you for requesting information about your Personal Information or our privacy practices?
How do we know that it is really you requesting your Personal Information?
What safeguards have we implemented to protect your Personal Information? How do you contact us regarding access to your Personal Information or our privacy practices
1. What is Personal Information? “Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, contact information, personal mailing address, date of birth, information that relates to your physical or mental health, including information that consists of the health history of your family, information related to the providing of healthcare to you, including the identification of a person as a provider of healthcare to you, medical information (such as your date of surgery), type of surgery, type and size of products, current and previous product usage information, health care provider information (including your applicable account information with such health care providers), and Get Truman usernames and passwords. Personal Information, however, does not include your name, business title or business address and business telephone number in your capacity as an employee of an organization.
2. How do we collect your Personal Information? We will always collect your Personal Information by lawful means. We may collect Personal Information from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent, or as otherwise required or permitted by law.
Whenever Get Truman requests Personal Information, we will explain the purposes for which that Personal Information is required. The collected Personal Information will be used only for the stated purpose, a requisite ancillary purpose, or for such other purposes to which the customer may later consent. Individuals should not provide Get Truman with any Personal Information that is not specifically requested.
3. Where do we store your Personal Information? We will keep the Personal Information that we collect either at the Get Truman offices or our service provider’s data centres in Canada.
4. How do we use your Personal Information? The collection, use, and/or disclosure of Personal Information in the business context is essential to the conduct of many of Get Truman’s business functions. Get Truman collects and uses Personal Information in a lawful manner and only when it is reasonably necessary to do so for the provision of requested services, products, or information or as may be required or permitted by applicable laws. We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.
We generally use your Personal Information for the following purposes (the “Purposes”):
to facilitate and administer your access to the Get Truman Site, and your use of the Get Truman Site’s functionality; to track your purchases through the Get Truman Site and arrange for refill;
to facilitate communications with third-party service providers with whom we have a contractual relationship such as, Physicians, Nurse Practitioners and Pharmacists, which assist Get Truman with its business activities; to advise you about new programs and services that may be of interest to you; to respond to your inquiries, complaints or requests; to collect opinions and comments in regard to Get Truman’s operations; to investigate legal claims; such purposes for which Get Truman may obtain consent from time to time; and such other uses as may be permitted or required by applicable law.
5. To whom do we provide your Personal Information? Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Access to Personal Information is limited to Get Truman employees on a “need-to-know” basis or where their duties reasonably require such information, agents with whom Get Truman contracts to carry out business activities for Get Truman, and, to the extent applicable, certain companies with which Get Truman may conduct joint programs.
We may need to disclose your Personal Information to our subsidiaries and affiliates, certain third-party agents, service providers, or professional advisors, in carrying out the requested services or as necessary for completing the otherwise permitted uses of Personal Information only to the extent that may be reasonably expected to deliver the services or improve the provision of the services. In such circumstances, Get Truman shall ensure that any such parties having access to your Personal Information have appropriate safeguards in place to reasonably ensure the protection of your Personal Information and shall be prohibited from using your Personal Information for any other purpose. Personal Information handled by any such parties is governed by this Privacy Statement and applicable privacy or data protection legislation.
For example, we may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as, Physicians, Nurse Practitioners, Pharmacists and service providers that provide telephone support or data storage or processing. Get Truman requires these service providers to keep Personal Information confidential and to use and/or disclose Personal Information only to perform functions for Get Truman and in accordance with Get Truman’s instructions and this Privacy Statement.
We may also be required to, subject to applicable law, use and/or disclose Personal Information in connection with a contemplated or actual reorganization of its business, when seeking financing or in connection with an assignment, sale, or other transaction involving the disposal of all or part of its business or assets (in which case the use of your personal information by the new entity would continue to be limited by applicable law), or as otherwise permitted or required by law.
In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
Get Truman may disclose Personal Information if required to do so by law enforcement officials, regulatory bodies, or government agencies to comply with any legal requirements or legal processes. Get Truman may also disclose Personal Information to protect and defend our legal rights or against legal claims or in connection with an emergency that warrants use or disclosure of the information or to protect the personal safety of an individual, in other circumstances for public security or for other public interest purposes.
6. When and how do we obtain your consent? We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances. In limited circumstances, we may rely on a third party to obtain your consent to the sharing of your personal information with us. You may withdraw your consent by providing us notice. You may expressly instruct that your personal health information not be used or disclosed for healthcare purposes without your consent.
7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties? We ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Statement and our privacy practices.
8. How long will we use, disclose or retain your Personal Information? We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.
9. How can you review your Personal Information that we have collected, used or disclosed? If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by law and subject to certain legal restrictions, to do so. Such legal restrictions include, without limitation, if providing access to the Personal Information would impede a criminal investigation or result in the disclosure of other protected information. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.
10. How do you know that the Personal Information we have on you is accurate? We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.
11. What if the Personal Information we have on you is inaccurate? At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
12. How fast will we respond to your written requests? We will attempt to respond to each of your written requests not later than 30 days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of Canada and/or the Information and Privacy Commissioner of Ontario in respect of this time limit.
13. Are there any costs to you for requesting information about your Personal Information or our privacy practices? We will not charge any costs for you to access your Personal Information in our records or to access our privacy practices without first providing you with an estimate of the approximate costs, if any.
14. How do we know that it is really you requesting your Personal Information? We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
15. What safeguards have we implemented to protect your Personal Information? We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees, who are granted access to your Personal Information, are those with a business ‘need-to-know’ or whose duties reasonably require such information. However, you acknowledge that the security of any data transmission over the Internet or data storage systems cannot be guaranteed.
16. How do you contact us regarding access to your Personal Information or our privacy practices? All comments, questions, concerns or complaints regarding your Personal Information, this Privacy Statement or our privacy practices, should be forwarded to our Privacy Officer at the following email address: [email protected]. Any complaints received regarding Get Truman’s use or handling of Personal Information will be investigated within a reasonably timeframe. Upon concluding the investigation, the Privacy Officer will respond to the complaint and, if necessary, Get Truman will take appropriate measure to rectify the situation and maintain compliance with applicable law.