The purpose of this Privacy Statement is to inform you about the types of Personal Information Cleveland Clinic (as follows, “Cleveland Clinic” “we” or “us”) collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. This Privacy Statement is supplemented by our Notice of Information Practices, which explains how we collect, use and disclose personal health information.
We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.
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 and our Privacy Policy, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.
The following topics will be covered in this Privacy Statement:
1. To which companies does this Privacy Statement apply?
This Privacy Statement applies to the collections, uses and disclosures of Personal Information by Cleveland Clinic. This Privacy Statement does not apply to other websites that we have linked to our website. On the Cleveland Clinic links page, we offer links to other websites operated by entities other than Cleveland Clinic. We try to link only with websites that share our values, however, you should check the privacy policy of any linked website to understand their personal information collection practices. We are not responsible for the content or information collection policies of such websites.
2. What is Personal Information?
“Personal Information” is any information that is identifiable with you. This information may include but is not limited to your name, mailing address, phone number and email address. 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. For the purposes of this Privacy Statement, Personal Information does not include personal health information, which is addressed in our Notice of Information Practices.
3. How do we collect your Personal Information?
We will always collect your Personal Information by fair and lawful means. We often collect Personal Information from you and from third party service providers, where we have obtained your consent to do so or as otherwise permitted by law.
4. Where do we store your Personal Information?
We will keep the Personal Information that we collect at our offices at
Cleveland Clinic Canada
Brookfield Place, Suite 3000
181 Bay Street, Box 818
Toronto, Ontario M5J 2T3
Our service providers may, from time to time, also hold your Personal Information in connection with purposes for which you provided your consent.
5. How do we use your Personal Information?
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”): (i) responding to your inquiries; (ii) including you on our mailing list; (iii) including you in our fundraising activities; (iv) providing health care; (v) planning, delivering and monitoring patient care programs or services; (vi) risk management or activities to improve quality of care or quality of any related program or service; (vii) processing, monitoring, verifying or reimbursing claims for payment under any Act; (viii) research, as approved by a Research Ethics Board; or (ix) as otherwise permitted or required by law.
6. To whom do we provide your Personal Information?
We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.
For example, we may disclose 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 – for example, service providers may be used to administer the website.
We will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquiror in connection with a transaction involving the sale of the business of Cleveland Clinic 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, and you should note that while such 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.
7. When and how do we obtain your consent?
We 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.
8. 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 retained 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 Policy and practices.
9. How long will we utilize, disclose or retain your Personal Information?
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, 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.
10. How can you review your Personal Information that we have collected, utilized or disclosed?
If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.
11. 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.
12. 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.
13. How fast will we respond to your written requests?
We will attempt to respond to each of your written requests not later than thirty (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 federal Privacy Commissioner in respect of this time limit.
14. Are there any costs to you for requesting information about your Personal Information or our Privacy Policy or practices?
We will not charge any costs for you to access your Personal Information in our records or to access our Privacy Policy or practices without first providing you with an estimate of the approximate costs, if any. You may withdraw your requests for access to information by notifying us within the thirty (30) day notice period disclosed on the estimate. If you do not notify us within such thirty (30) day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within thirty (30) days. If, after the expiry of this second thirty (30) day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.
15. 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.
16. 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.
17. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?
All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and practices, should be forwarded to our Privacy Officer as follows in writing:
Cleveland Clinic Canada
Brookfield Place, Suite 3000
181 Bay Street, Box 818
Toronto, Ontario M5J 2T3
Attention: Chief Privacy Officer
Please call 416.507.6600 and ask for our privacy officer for more information
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