TORONTO HEARING SERVICES PRIVACY POLICY

Last Updated Effective: December 2021

Information protected by HIPAA will be governed by our practice’s HIPAA Notice of Privacy Practices, which is available upon request.

This privacy notice discloses the privacy practices for Toronto Hearing Services with respect to non-HIPAA-protected information.
By using this website, you are agreeing to the terms of this Privacy Policy.

If you are a California resident, please see our California Privacy Rights Section below.

Information We Collect

Information you Voluntarily Provide: We may receive personal information when you interact with our Website or our services. For example, when you:

• Request information regarding our practice;
• Participate in surveys, sweepstakes or other promotional activities online or in any other venue (including on any social media platform);
• Subscribe to our newsletters, programs, promotional emails or other materials;
• Apply for a job, submit your resume/CV or create a candidate profile; or
• Contact us with your questions/comments.

Note that we may also receive information about you from third party sources, such as your family members.

Your interactions with our website and emails: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the website and our services, to improve the content and performance of our website and services, to manage your online shopping cart, and to track users’ movements around the website. We may also link this automatically-collected data to personal information. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that we may use on our website please see our section regarding Cookies below.

How We Use Personal Information

We use the information and data we collect principally in order to operate our website and practice and to respond to your requests. More specifically, we may use your personal information to:

• Send communications to you, such as to respond to your requests
• Administer contests, promotions, surveys or other site features;
• Customize, analyze and improve our practice (including the content and advertisements on our website);
• Comply with our legal and regulatory responsibilities and to enforce our rights;
• Authenticate users and to provide for the safety and security of our website and otherwise prevent fraud and other prohibited or illegal activities;
• Protect the security of our website and our practice; or
• Otherwise, as disclosed to you at the point of collection.

Disclosing Personal Information

Your personal information may also be shared with:

• Parties who support our practice, such as technical support, delivery services, professional advisors as well as web-hosting providers, analytics providers, customer-relationship management software providers and other information technology providers;
• Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues; and
• To our affiliated entities and in connection with the sale, assignment or other transfer of our practice.

Except as described above, we will not disclose your personal information to third parties for their own marketing purposes without your consent.

Choices Regarding Our Collection and Use of Your Information

We may offer you choices regarding the information we collect and how that information is used and shared. These choices may include the ability to access, update or delete information that you have provided to us or information that we have collected through your use of our website. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us. To inquire about making any of these requests please contact us below. Note that if at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

How We Secure Your Personal Information

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only individuals who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Links to Other Web Sites

You should be aware that when you are on the website you could be directed to other sites beyond our control. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a website that is linked to one of our websites, you should consult that site’s privacy policy before providing any personal information. Please note that we are not responsible for the privacy practices of third parties.

Collection and Use of Children’s Personal Information

Our website is directed to people who are at least 13 years old or older. If any parent, guardian or other responsible adult becomes aware that we have collected personal information from a child under the age of 13, please contact us below.

Cookie Guide

As with many websites, our website and services (such as our email updates) use a standard technology called a “cookie” and other similar technologies (such as, pixels, tags and web beacons), which are small data files that are transferred to your computer when you use our Website and services. These technologies automatically identify your browser whenever you interact with our website and services.

There are different types of cookies and other technologies used on our website and services, notably:

“Session cookies” – These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).

“Persistent cookies” – These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.

“Web Beacons/Pixels” – Some of our web pages and emails may also contain small electronic images known as web beacons, tags, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email offers.

We use cookies and other tracking technologies to:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into and manage your account and to place orders.
• Analytical/performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website and services when they are using it. This helps us to improve the way our website and services work, for example, by ensuring that users are finding what they are looking for easily. We also may use these tools to help deliver analytics to our Practice partners to give them insight into the Practice website.
• Functionality cookies. These are used to recognize you when you return to our website and services. This enables us to personalize our content for you, greet you by name and remember your preferences.
• Advertising/Targeting cookies. These cookies record your visit to our website and services, the pages you have visited and the links you have followed. We will use this information to make our website and services and the advertising displayed on it and on third party sites more relevant to your interests. We may also share this information with third parties for this purpose.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from our website you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It’s also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser’s “Help” function or alternatively, you can visit https://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Third-Party Ad Serving & Audience and Traffic Measurement Services

The website may use third party network advertisers to serve advertisements you may see. Network advertisers are third parties that display advertisements based on your visits to the Site and other websites you have visited. Third-party ad serving enables us to target advertisements to you for products you might be interested in.

Our website is in compliance with the Ad Choices Self-Regulatory Program for Online Behavioral Advertising. The goal of Ad Choices is to provide you with information about how online advertising works and the choices you have.

You may visit the https://www.aboutads.info/choices page to learn more about online behavioral advertising and to see your opt-out choices from companies that are participants in the Self-Regulatory Program for Online Behavioral Advertising.

Please note that if you choose to opt out, you will still see ads, but these ads will not be customized based on your interests generated from your visits over time and across different websites. In addition, the preferences you select on the https://www.aboutads.info/choices page may not apply to mobile devices. Due to the differences between using apps and websites on mobile devices, opt-outs will need to be set for both browsers and apps.

Do-Not-Track

Some browsers have incorporated a Do-Not-Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our website.

Social Media & Features

Our website may include social media features, including the Facebook “Like” button and Twitter “Follow” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

Users Outside the United States

Toronto Hearing Services is located in the United States. The website are directed solely towards users who reside in the United States. If you choose to use the website from outside the United States, you are consenting to the collection, storage, processing, and transfer of your information in and to the United States, pursuant to the laws of the United States.

Notwithstanding the forgoing, we will honor the following requests from users:

• If the processing of personal data is based on your consent, the right to withdraw consent for future processing of that data.
• The right to request from us access to and rectification of your personal data.
• Subject to reasonable limitations, the right to request restriction of the processing of your personal information.
• Subject to reasonable limitations, the right to request erasure of your personal data.

You may contact us using any of the methods described in the “Contacting Us” section of this Privacy Policy below to exercise these rights. We may require you to verify your identity to exercise any of these rights.

Terms Applicable To California Residents

This Section provides additional terms that apply to residents of California only to the extent that the California Consumer Privacy Act (the “CCPA”) is applicable to Toronto Hearing Services. In the event of a conflict between this Section and the remainder of this Privacy Policy, this Section shall take precedence for California residents.

California Shine The Light. Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us below to receive this information.

California’s “Do Not Track” Requirement. We do not react to “Do Not Track” or “DNT” browser signals at this time.

The Collection, Source, Purpose and Sharing of Your Personal Information.

• To learn the categories of Personal Information we collect, please review the section entitled “Information We Collect” above.
• To learn the categories of sources from which your Personal Information is collected, please review the section entitled “Information We Collect” above. To learn the purposes for collecting your Personal Information, please review the section entitled “How We Use Personal Information” above.
• To learn the categories of third parties and service providers with whom we share your Personal Information, please review the section entitled “Disclosing Personal Information” above.

Categories of Personal Information Disclosed For A Business Purpose

In the last 12 months, we disclosed the following categories of Personal Information for our business purposes, or one of our service provider’s business purposes. See the section above titled “Personal Information We Collect” for more detail on the type of Personal Information in each category.

Your information may be “sold” as defined under the CCPA, which defines “sale” as the disclosure of Personal Information to a third-party for monetary or other valuable consideration. California’s definition of sale is broad and encompasses many types of data transfers. However, we do not “sell” any consumer data in the traditional sense for monetary compensation.

In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure:

• Identifiers, such as name, postal address, IP address, account credentials and email address;
• Personal information, as defined in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as contact information and financial information;
• Characteristics of protected classifications under California or federal law, such as gender;
• Commercial information, such as transaction information and purchase history;
• Internet or network activity information, such as browsing history and interactions with our website;
• Geolocation data, such as Internet Protocol (IP) location;
• Audio, electronic, visual and similar information, such as call and video recordings; and
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

Your Rights to Access and Deletion. The CCPA provides additional rights to California residents. Subject to exceptions permitted by applicable laws and verification of your identity, if you live in California, you may exercise the following rights with regard to your Personal Information. Capitalized terms in this Section that are not defined elsewhere in this Privacy Policy have the definitions set forth in the CCPA.

• Right to Access. You have a right to access any of the following that occurred in the prior 12-month period:
  • The categories of Personal Information we collected from you;
  • The categories of sources from which the Personal Information was collected;
  • The specific pieces of Personal Information that we have collected from you (i.e. “data portability”);
  • The categories of third parties with whom we shared your Personal Information;
  • The categories of Personal Information that we Sold or disclosed for a Business Purpose; and
  • The Business or Commercial Purpose for collecting or selling your Personal Information.
• Right to Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

How to Exercise Your Rights of Access and Deletion

How to Exercise Your Rights. To exercise your rights under the CCPA, you may contact us at any of the following:

By Telephone: 647-496-3313

By E-mail

By Regular Mail:

Toronto Hearing Services
203-377 Church Street
Markham, Ontario L6B 1A1

Who May Exercise Your Rights. If you are a California resident, only you or a person that you authorize to act on your behalf may make a request related to your Personal Information. A parent or legal guardian may make a request on behalf of their child. If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

Verifiable Consumer Request. In order to verify your request to access or delete your data, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; and (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

When We Will Respond. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination. You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA.

Terms Applicable To Canadian Residents

Right of Access. Under Canadian privacy laws you have the right:

• To be informed of the existence, use and disclosures of your Personal Information;
• To receive an account of the uses that have been made of your Personal Information by us and any third parties to whom it has been disclosed;
• To be given access to your Personal Information; and
• To challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.

We may require that you provide information verifying your identity before we provide this requested information to you. To obtain such information please contact us below.

Legal Disclosures and Lawful Requests. We and our service providers and affiliates may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Changes to This Privacy Statement

We will occasionally update this Privacy Policy. If we make changes to this Privacy Policy or make any material changes to how we use your personal information, we will revise this Privacy Policy to reflect such changes and revise this Privacy Policy’s effective date, included at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we are using and protecting your personal information.

Contacting Us