Last Update: August 2018 SEC3URE is an online service provided by Intellicentrics Solutions Inc. and its affiliates (“Intellicentrics” or “We”)  that (1) allows SEC3URE’s healthcare industry representative (the “Healthcare Industry Representative”) members to be credentialed for purposes of providing them with access to healthcare providers’ hospitals in the course of discharging their role as Healthcare Industry Representatives and (2) allows SEC3URE’s healthcare provider members to screen and track Healthcare Industry Representative members who access their hospitals in the course of discharging their role as Healthcare Industry Representatives. To this end, SEC3URE’s healthcare provider members can view profiles of the Healthcare Industry Representative members. To enable all of SEC3URE’s members to reap the benefits of credentialing, we request and display some personal information of SEC3URE’s Healthcare Industry Representative members to SEC3URE’s healthcare provider members, which information allows our healthcare provider members to identify the Healthcare Industry Representative members and make informed decisions regarding their business partners. SEC3URE’s Healthcare Industry Representative members can change the portion of their profile information that they have supplied to Intellicentrics at any time. At Intellicentrics, we are committed to protecting the privacy of any personal information in our custody and control. Intellicentrics has developed this privacy policy (the “Privacy Policy”) to describe the way in which we collect, use, disclose, retain, and otherwise manage personal information, including the personal information collected through the Website www.sec3ure.ca (the “Website”). For the purposes of this Privacy Policy, “Personal Information” means “personal information” as defined in the Personal Information Protection and Electronic Documents Act (PIPEDA) or, other provincial-level privacy legislation, as applicable.  “Personal Health Information” has the meaning defined in the Personal Health Information Protection Act (Ontario) or other applicable health privacy legislations. The Personal Information we collect about you Personal Information that we may collect about you, including through the Website, may include your:
  • Name;
  • Contact information, such as your address, telephone number, and email address;
  • Employment-related information, such as your employer and position;
  • Education and training information;
  • Confirmation that you do not have a criminal record (we do not collect or store the details of actual criminal record histories);
  • Health information, such as any vaccination history and proof of immunization;
  • Information required to meet hospital policy;
  • Information regarding your previous interaction as a vendor at specific hospitals or healthcare facilities you select through the Website, such as training records, and access history; and
  • Any other information in questions, comments, complaints or other inquiries you may submit to us through one of our customer service or support points of contact, the Website, or otherwise.
We may collect Personal Information directly from you, your authorized representatives (such as your employer), or from medical training, licensing, regulatory or credential verification organizations and public records. Intellicentrics will limit the collection of both the amount and the type of Personal Information to that which is reasonably necessary to fulfill the identified purposes or as otherwise identified in this Privacy Policy. How we use your Personal Information Intellicentrics may use your Personal Information, and you hereby consent to such use, for the following purposes:
  • To allow Intellicentrics to provide its services, to improve its services and the Website, and to manage Intellicentrics’ relationship with you;
  • To assist the specific hospitals and healthcare facilities that you select with their vendor credentialing processes;
  • To assist the specific hospitals and healthcare facilities that you select in maintaining a secure database of authorized vendors;
  • To provide vendor access control programs to the specific hospitals and healthcare facilities that you select;
  • To verify your professional credentials and compile your credential information;
  • To provide the specific hospitals and healthcare facilities that you select with access to your vendor profile;
  • To set up, manage and offer other products and services that meet your needs and to otherwise provide the products and services that you request;
  • To respond to your questions, comments, complaints or other inquiries;
  • To send you information that you request or otherwise contact you; and
  • To meet our legal and regulatory requirements.
User profile information, including, without limitation, the pictures and names of Healthcare Industry Representative members, is displayed on the Website in order to facilitate interaction between and among Healthcare Industry Representative members and healthcare provider members on the Website. With the exception of allowing healthcare provider members to review Healthcare Industry Representative members profiles, and unless a Healthcare Industry Representative member otherwise consents to having his or her email address shared or displayed, we will not share or display to others a Healthcare Industry Representative member’s email address others. Healthcare provider members can communicate with each other on the Website through the SEC3URE service without disclosing their email addresses. When and to whom we may disclose your Personal Information In order to allow us to provide our services, including the SEC3URE service, to the specific hospitals and healthcare facilities that you select, your Personal Information may be disclosed to these organizations at your request and on your behalf and you hereby consent to such disclosure. The vendor with which you are employed may also have access to your Personal Information for the purposes of managing its account with us. We may also share some or all of your Personal Information in connection with or during the negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving a sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. If another company acquires our company, business, or assets, that company may possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this privacy policy. We may anonymize or aggregate your Personal Information (excluding your Personal Health Information) so that you are not identifiable, and provide that information to our partners or use that information for marketing or promotional items. However, except as described elsewhere in this policy, we do not disclose aggregate information to a partner in a manner that would identify you personally as an individual. Intellicentrics will not disclose, trade, rent, sell or transfer your Personal Information without your consent, except as otherwise set out in this Privacy Policy. Service Provider Arrangements: We may transfer (or otherwise make available) your Personal Information to third parties who provide services on our behalf and you hereby consent to such transfer. For example, we may use service providers to (i) authorize and process payments, (ii) manage the Website, computer and other business systems, and (iii) conduct credential verifications. All of our service providers are required to maintain the confidentiality and security of your Personal Information and are prohibited from using your Personal Information for any purpose other than providing the services on our behalf or as otherwise required by applicable law. For information about the manner in which our service providers treat your Personal Information, contact us as set out below. Legal: Intellicentrics and our service providers may disclose your Personal Information (i) to a person who, in the reasonable judgment of Intellicentrics is providing or seeking the information as your agent, (ii) to government authorities, insurers, benefit providers, consultants or agents as reasonably required to establish, manage or terminate contractual and partnership relationships and agreements or in the case of a contravention of law, or, (iii) as otherwise required or permitted by applicable law. We may also disclose Personal Information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property. The need for accuracy Failure to provide Intellicentrics with accurate, complete, and up-to-date information may limit our ability to provide our services, including the SEC3URE service. Accordingly, Intellicentrics relies on the diligence of users to supply information that is current, complete and accurate, and to update their information as appropriate. Retention of your Personal Information We have implemented procedures to retain your Personal Information only as long as necessary to meet the purposes for which it was collected, including as set forth in this Privacy Policy, or to otherwise meet legal requirements. The length of time Intellicentrics retains Personal Information varies depending on the purpose for which it was collected and the nature of the Personal Information. The need for security We have implemented reasonable administrative, technical and physical safeguards designed to protect your Personal Information against loss, misuse or unauthorized access, disclosure, alteration or destruction. For example, our employees are made aware of their privacy obligations and physical access to those areas, where Personal Information, is processed or stored is restricted to authorized employees only. To provide you with increased security on the Website, access to certain Personal Information will be protected by a user-specific username and password that you select. You should not disclose your username or password to anyone. We will never ask you for your password in any unsolicited communication. Intellicentrics restricts access to member information to those of its employees and contractors who need access to perform their job functions, such as Intellicentrics’ customer service personnel and technical staff. Please note that Intellicentrics cannot guarantee the security of member account information or any communication between Intellicentrics and you. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of member account information at any time. Access to your Personal Information You have the right to access, update, and correct inaccuracies in your Personal Information in our custody and control, subject to certain exceptions prescribed by law. You may access and update certain of your Personal Information by signing into your account and editing your profile. You may request access, updating and corrections of inaccuracies in other Personal Information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain Personal Information for the purposes of verifying your identity. Where do we store your Personal Information Your Personal Information is stored in secured locations and on servers controlled by Intellicentrics, located in Canada either at the offices of Intellicentrics or at the offices of our service providers. Additional information about the Website We collect the IP (Internet protocol) addresses of all visitors to the Website and other related information such as page requests, browser type, operating system and average time spent on the Website. We use this information to help us understand the Website activity, and to monitor and improve the Website. Cookies: Our Website uses a technology called ‘cookies’. A cookie is a tiny element of data that the Website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. If you have an account on the Website, these cookies may let us know who you are and will provide us with information that we use to personalize the Website in accordance with your preferences. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, you may find that certain parts of the Website will not function without the use of cookies. Advertising: Cookies, web beacons, tracer tags and similar technologies help us to improve, deliver, and understand how you use the Website and the ads that are served to you on and off the Website. For example, we may use third-party ad networks to serve our ads on other websites. These ad networks may use cookies, tracer tags or web beacons to report certain information about your visits to the Website and the websites that advertise and feature links to the Website, in order to serve and measure the effectiveness of our ads. In addition, ads appearing on the Website may be delivered to users by third-party ad networks, which may use cookies or similar technologies. These cookies allow the ad network to recognize your browser each time they serve you an ad. This information allows ad networks to tailor ads that may be of interest to you. Third party links: Our Website may contain links to third-party sites that Intellicentrics do not own or operate. Also, links to the Website may be featured on third party websites on which we advertise. We provide links to third party websites as a convenience to our users. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your Personal Information. This Privacy Policy only governs information collected on the Website. Please be aware that, whenever you voluntarily post public information to your profile or to the profile of others, that information may be accessed by healthcare provider members. Withdrawal of Consent If you have provided us with Personal Information and wish to withdraw your consent to its retention, use, or disclosure, please contact us at one of the points of contact outlined below. You may withdraw your consent, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent to certain uses of your Personal Information, we may no longer be able to provide certain services. Where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, maintaining reasonable business records and disclosures where required by law). Changes to this privacy policy This Privacy Policy may be updated periodically to reflect changes to our Personal Information practices. The revised Privacy Policy will be posted on the Website with the date on which it was last updated. Intellicentrics will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law. Who to contact with questions or complaints Any questions or complaints you have regarding our privacy practices may be directed to our Privacy Officer at the contact information set out below. Customer Service 1-877-885-1420 customerservice.ca@intellicentrics.com 1111 Dr. Frederik-Philips Blvd Suite 600 Montreal, Quebec Canada H4M 2X6