PRIVACY POLICY
LAST REVISED: JANUARY, 4, 2023
At Eclipsys Solutions Inc. (“Eclipsys”), we make it a priority to ensure your personal information is kept confidential and secure, and we have strict safeguards in place to protect it. We protect your privacy by complying with applicable privacy laws and regulations in Canada, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
This Policy describes how we collect, use, disclose, and protect the personal information of our customers and users of its Website (“you”), the type of information we may collect from you, and our practices for collecting, using, maintaining, protecting and disclosing that information.
We will only use your personal information in accordance with this Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
This Policy applies to all information we collect, use or disclose about our customers using our services, as well as our users of the Website.
Any changes to this policy shall be posted on our website for public review.
This Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third-party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
Please read this Policy carefully to understand our policies and practices for collecting, using, disclosing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website or services. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This Policy may change from time to time. Your continued use on this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.
DEFINITIONS
Personal Information: Information about an identifiable individual, in any form. It includes, but is not limited to: race, ethnic origin, color, age, marital status, religion, education, medical, criminal, employment or financial history, address and telephone number, birth date, numerical identifiers such as social insurance numbers, and personal views or opinions.
However, Personal Information does not include “business contact information”, which means information such as an employee’s name, title, business address, telephone number or email addresses that is collected, used or disclosed solely for the purpose of communicating with that person in relation to their employment or profession.
COLLECTION AND USE OF YOUR PERSONAL INFORMATION
Eclipsys will collect and use your information for different purposes depending on whether you are a Website Visitor or a Customer.
Website Visitors
Through the Website, we collect and use several types of information from and about you, including:
Personal information.
- Non-personal information, that does not directly or indirectly reveal your identity or directly relate to any identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
- Technical information, including your login information, audit and traceability logs which may include various information such as IP addresses, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
- Non-personal details about your Website interactions, including the full Uniform Resources Locators (URLs), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
Customers
Depending on the nature of the commercial activity, Eclipsys generally collects your name, postal address, email address, telephone number, location data and payment information
HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms, providing feedback or corresponding with us by phone, email, or otherwise.
- Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
Information You Provide to Us
The information we collect directly from you on or through our Website may include:
- Personal information during registration such as a username, password, and contact information (such as name, e-mail address, and company name).
- Personal information for security questions to help you recover your password.
- Information that allows us to access other websites or services that wish to interact with our Website.
- Information that you provide by filling in forms on our Website. This includes information provided at the time of signing up to use our Website. We may also ask you for information when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses) if you contact us.
- Details of transactions you carry through our Website and or the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and does not include personal information and we may maintain it or associate it with personal information we collect in other ways that you provide to us. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We may use cookies for example to permit you to save your username and password between sessions. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Third-party collection of information
Except as otherwise expressly set out below, this Policy only addresses the use and disclosure of information we collect, use, or disclose about you. To the extent that you disclose your information to other parties, different rules may apply to their use or disclosure of the information you disclose to them.
Notably, Eclipsys employs a third-party service provider to host the Website, to manage server requirements and to provide a secure billing service. Information provided directly to these service providers which is not provided to Eclipsys is not within our custody or control, notwithstanding that they the information may be provided to such third parties through our website.
From time to time, we may engage other third-party service providers to assist with the development, management or maintenance of our Website. At times, this may require the disclosure of certain personal information. We will ensure that where it is necessary to engage third party service providers to process personal information which we collect, use or disclose, such service providers are bound by contract to take comparable precautions in their handling of such information to those set out below.
HOW WE USE YOUR INFORMATION
Eclipsys generally uses collected personal information for the following purposes:
- To process and fulfill transactions including sending confirmation of your transaction and to process payments;
- To communicate with you about our products, services and promotions;
- To address problems with and improve our services;
- To allow you to use our services and technologies;
- To allow you to customize our services; and
- To develop and enhance our services and products.
DISCLOSURE OF YOUR INFORMATION
We may disclose non-personal information, such as aggregated information about our users, without restrictions.
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
- To subsidiaries and affiliates.
- In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Eclipsys’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Eclipsys about our customers and users is among the assets transferred.
- To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by use when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
- To enforce or apply our terms of service and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Eclipsys, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide as described in this Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We will ensure that all of your information collected by the Website is processed and stored in Canada.
LIMITING COLLECTION, USE AND DISCLOSURE
Unless you are otherwise notified in advance, Eclipsys collects only the information that is necessary for the purposes outlined in this Privacy Policy. Eclipsys also limits its use of collected personal information to the purposes for which it was collected, except with an individual’s consent or as required by law.
Eclipsys does not share, rent, exchange or otherwise disclose personal information to outside third parties except where authorized or required by law.
Eclipsys does use external service providers to assist in various functions such as processing financial transactions, data analysis, and hosting services. Where personal information is transferred to or shared with external service providers, we require the providers to comply with the terms of this Privacy Policy and we restrict them from using of disclosing the personal information for any purpose other than those necessary to complete their provision of services to Eclipsys.
SECURING PERSONAL INFORMATION
Eclipsys uses security measures to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. It uses measures that are appropriate to the sensitivity of the information, including:
- Physical measures, such as locking filing cabinets, restricting access through the use of security passes and limiting access to personal information to a “need to know” basis;
- Technological measures such as the use of passwords and encryption and firewalls; and
- Procedural measures such as shredding sensitive personal information.
Eclipsys uses third party service providers to process and store data on its behalf, including cloud service providers. Some of these service providers may use servers which are based in the United States. As a result, your personal information may be stored on or transmitted across servers located in the United States while in the custody or control of Eclipsys.
DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such non-personal information for any legitimate business purpose without further notice to you or your consent.
LINKS TO THIRD PARTY WEBSITES
Our Website and Applications may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third-party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we do not accept responsibility or liability for these policies. We encourage you to read the privacy policy of every website you visit before disclosing personal information.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the methods provided at “Accessing Your Personal Information & Compliance”, below. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
ACCESSING YOUR PERSONAL INFORMATION & COMPLIANCE
To request a copy of your personal information held by Eclipsys or to notify us of inaccuracies and request corrections, please submit a written request to the Data Privacy Officer at 343 Preston Street, Suite 130, Ottawa (Ontario) K1S 1N4 or 613-686-6344. You will be required to provide acceptable proof of identification prior to Eclipsys providing you with the requested information.
If you would like to make a complaint regarding the management of your personal information, or our compliance with PIPEDA we encourage you to contact the Data Privacy Officer at 343 Preston Street, Suite 130, Ottawa (Ontario) K1S 1N4 or 613-686-6344. If we are unable to resolve your complaint, you can contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca at the following address:
Office of the Privacy Commissioner of Canada
30 Victoria St.
Gatineau, QC K1A 1H3
Toll free: 1-800-282-1376
Tel: (819) 994-5444
Fax: (819) 994-5424
E-mail: info@priv.com.gc.ca