Introduction and Scope
Please note that Clinic Sense provides the ClinicSense Service on behalf of its customers and clients, such as massage clinics and businesses (“Clients”). As such, ClinicSense processes Personal Information collected through the ClinicSense Service on behalf of the Client as the Client’s service provider. As such, the Client is ultimately accountable for and in control of your Personal Information collected through the ClinicSense Service.
We will also collect Personal Information directly from individuals who contact us to ask a question or request information about our company and services, or otherwise submit Personal Information to us through our website contact form. In such cases, ClinicSense will be acting as the controller of such Personal Information.
•Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of ClinicSense. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction.
•ClinicSense Service: means the ClinicSense web-based service clinic management service provided by ClinicSense.
•Disclosure: making Personal Information available to a third party for that party’s own use.
•Personal Information means information, recorded in any form, that identifies an individual or that could be used to identify an individual, but does not include aggregated, anonymized, or depersonalized information that cannot be associated with an individual or business contact information, such as your name, title or position, business address, business telephone or fax number
•Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of ClinicSense.
•Use: the treatment, handling, and management of Personal Information by and within ClinicSense.
ClinicSense is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. ClinicSense shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
ClinicSense shall implement policies and practices to give effect to these principles, including:
a. implementing procedures to protect Personal Information;
c. training staff and communicating to staff information about the organization’s policies and practices.
As noted above, when we collect Personal Information through the ClinicSense Service it is on behalf of our Client as the Client’s service provider. In these circumstances, the Client is accountable for the Personal Information that we process on their behalf.
What Information Do We Collect?
a. Personal Information
Personal Information that ClinicSense collects includes, but is not limited to:
•Information that you provide when you contact us to ask a question or request information about our company or service, or otherwise submit Personal Information to us with your communications or through our website contact form.
•Personal Information of our Client’s customers and patients collected through the ClinicSense Service. This includes:
◦Contact information: such as name, e-mail address, address, birthdate, and phone number;
◦Financial information: such as credit card information to process payments for sessions, the name of your health benefits providing and your benefits provider account number;
◦Scheduling and booking related information;
◦Online identifiers, such as Internet protocol address; and
◦Personal Health Information: such as health history, COVID-19 related information, injuries, health conditions and treatment notes.
•Technical support records;
•Service requests and inquiries; and
•Any information that we collect from you that is intended to improve and personalize our services.
b. Non-Personal Information
Non-Personal Information (“NPI”) means information that is aggregated, anonymized or otherwise cannot be linked with any individual. ClinicSense collects NPI about individuals when they interact with our company website. For instance, NPI may include, but is not limited to, browser name, type of computer or device, IP address, geo-location information, pages accessed or visited, and technical information about a User’s means of connecting to the Site, such as operating system, Internet service provider utilized, and mobile network information. See the section below entitled “How does We collect, use and share NPI?” for more information.
How Do We Use Your Personal Information?
With respect to information collected through the ClinicSense Service, we collect and use such Personal Information in order to provide the service to our Clients, including utilizing our payment processor to provide payment services. This may also include responding to your questions on behalf of our Client.
With respect to all other Personal Information collected by us, we use Personal Information for the following purposes:
•to establish and maintain commercial relations with you;
•to respond to your questions that you send by email or our website contact form;
•subject to applicable law, to provide you with newsletters and articles;
•to improve the ClinicSense Service, and help us develop new services, tools and product features;
•to support our business functions such as internal business processes, security, marketing, and advertising; and
•to meet any legal or regulatory requirements.
How Long Will We Retain Your Personal Information?
ClinicSense will retain your Personal Information for as long as necessary to fulfill the purposes for which we collected the information, to ensure your compliance with our terms of service, and to comply with our legal or contractual obligations. When we act as a service provider to our Clients, we will retain such Personal Information in accordance with our Client’s instructions.
We respect your privacy and, unless otherwise required by law, we will not collect, use, transfer or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing your contact information in conjunction with a product inquiry is implied consent for ClinicSense to contact you.
In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when ClinicSense wants to use information for a purpose other than those identified above). The form of consent sought by ClinicSense may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, ClinicSense shall consider the sensitivity of the Personal Information and the reasonable expectations of the individual. ClinicSense will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
When we process your Personal Information as a service provider to our Client, our client is responsible for obtaining your consent and you will need to make any consent withdrawal request to the Client directly.
Do We Disclose or Transfer Your Personal Information to Others?
When we act as a service provider to our Clients, we will only collect, use and disclose your Personal Information in order to provide the ClinicSense Solution on the Client’s behalf in accordance with the Client’s instructions.
We may share your Personal Information with third party service providers that help us with our business operations or to support the ClinicSense Solution. For example, we may share your Personal Information to service providers that help with our operations or our products, including, without limitation, for customer service, billing, and payment processing. Such service providers may only use your Personal Information as provided herein.
We may also disclose your information, including Personal Information, in the event we sell or transfer all or a portion of our business or assets (including corporate reorganization, merger or amalgamation with another entity, dissolution or liquidation).
From time to time we may disclose your Personal Information to third parties under the following limited circumstances:
•when necessary to protect our safety, property or other rights, our representatives, customers and users of the ClinicSense Solution, including to detect and prevent fraud;
•with your consent; or
•when otherwise required or permitted by law.
Any Personal Information that we process as a service provider to our Client will remain under our Client’s control and will not be disclosed to a third party except on our Client’s instructions or when required by law.
How Do We Collect, Use and Share NPI?
ClinicSense uses NPI in an ongoing effort to better understand and serve our customers and to improve the content and functionality of our website.
Specific Uses of NPI by ClinicSense:
•To conduct internal research on our customers and potential problems to better understand and serve them, including usage patterns, demographics, interests and behaviors.
•To diagnose or service technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP.
•We use anonymized and aggregated information about Users interaction with our Site to test our systems, data analysis, developing new services and improving and/or personalizing your experience on our Site.
Data Processors in Other Countries
As discussed above, we may engage third party service providers to perform certain services on our behalf. These providers may store, process and transfer Personal Information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada. As a result, Personal Information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our service providers to maintain protections on personal information that are equivalent to those that apply in Canada.
If you have questions or suggestions you can contact us at:
How Do We Protect Your Personal Information?
ClinicSense protects your Personal Information by security safeguards appropriate to the sensitivity of the information. We maintain technical, physical, and administrative security safeguards to protect your Personal Information against loss, theft, and unauthorized access or disclosure. Any Personal Information that you provide to us is exchanged on a secure server. Although we take reasonable and appropriate measures to protect the security of your Personal Information, no data transmission over the Internet can be guaranteed to be completely secure.
You are solely responsible for maintaining the secrecy of your username, password, and any other account information. We also take reasonable steps to ensure that our employees, contractors and vendors are aware of the importance of maintaining the confidentiality of personal information and have signed confidentiality/non-disclosure agreements with them as applicable. We endeavour to limit access to Personal Information to those personnel that require access to such personal information on a ‘need to know’ basis in order to perform their obligations.
How May I Access and Modify My Personal Information or Make a Complaint?
If you have questions or concerns about Personal Information collected by us and would like assistance accessing that information and/or would like to confirm its accuracy, please contact us at firstname.lastname@example.org. In limited circumstances, we may not be able to provide you with access to your Personal Information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.
Please note that where we process your Personal Information as a service provider to our Client, you will need to make your request to the Client directly.
You may request to update and change your Personal Information in our control at the contact information set forth below. We shall endeavor to correct or complete any Personal Information which you advise us is inaccurate or incomplete. Where appropriate, the amended information shall be transmitted to third parties having access to such information. Where we process your Personal Information as a service provider to our Client, you will need to make your request to the Client directly.
Using the Site and Cookies
Third parties also place browser plug-in cookies on our site, including Flash cookies, also known as "local shared objects," to perform similar functions as browser cookies. Like normal browser cookies, these cookies are represented as small files stored on your computer. One method of preventing Flash cookies from being placed is to adjust your preferences in the Macromedia Website Privacy Settings Panel at macromedia.com
We comply with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law. You may have also opted in to receive email communications from us. If you opted-in to receive such communications, we may use the information to: communicate with you regarding our products, and promotions; provide you with other information that you request; and/or improve our product and service offerings.
You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. At any time, may opt-out of contact from us by clicking on the unsubscribe link in the e-mail. If you decide to unsubscribe, we will only contact you for the purposes allowed under applicable law.
ClinicSense reserves the right to modify and amend this Privacy Notice from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our website at https://clinicsense.com/privacy-policy/
If you have questions or suggestions you can contact us at:
21 Thorncrest Rd
Toronto, On, Canada
This policy was last updated March 21, 2023